Rajasthan High Court – Jodhpur
Urn: Cw / 15998U / 2026Ashok Kumar Manish … vs Joint Commissioner Of Income Tax … on 1 May, 2026
[2026:RJ-JD:20594-DB]
HIGH COURT OF JUDICATURE FOR RAJASTHAN AT
JODHPUR
D.B. Civil Writ Petition No. 8724/2026
Ashok Kumar Manish Kumar Huf, Through Its Karta Ashok Kumar
S/o Shiv Lal Golecha Aged About 61 Years R/o Arihant Colony,
Ward No. 23, Balotra, Rajasthan - 344022
----Petitioner
Versus
1. Joint Commissioner Of Income Tax, Range-3(R), Ju,
Aayakar Bhawan, Paota C Road, Jodhpur, Rajasthan -
342010
2. Income Tax Officer, Balotra, Shaheed Bhagat Singh
Circle, Balotra, 344022
3. Commissioner Of Income Tax, Appeal Addl/jcit (A)-8,
Aayakar Bhawan, M.k. Road, Mumbai, 400020
4. Central Board Of Direct Taxes, Through Secretary, Cbdt
Headquarters, North Block (Department Of Revenue),
New Delhi - 110001
----Respondents
For Petitioner(s) : Mr. Sharad Kothari
Mr. Kalpit Shishodia
Mr. Pranjul Mehta
Mr. Chirag Soni
Mr. Dinesh Kumar Suthar
For Respondent(s) : Mr. Sunil Bhandari
HON'BLE MR. JUSTICE ARUN MONGA
HON’BLE MR. JUSTICE SANDEEP SHAH
Order
Reportable
01/05/2026
Per: Arun Monga, J.
1. Petitioner is before this Court challenging the notice dated
23.03.2026 issued under Section 148 of Income Tax Act, 1961
(Annexure-2), sanction note dated 20.03.2026 and all other
consequential proceedings/actions.
2. Brief facts of the case are that the petitioner, a Hindu
Undivided Family (HUF) acting through its Karta Mr. Ashok Kumar,
resident of Balotra, Rajasthan, filed its return of income for A.Y.
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2022-23 on 22.07.2022 declaring total income of Rs. 8,24,770/-.
The return included business and interest income, with a tax
liability of Rs. 80,552/- and TDS of Rs. 7,15,391/-, resulting in a
claimed refund of Rs. 6,34,840/-. Upon processing under Section
143(1), the Centralized Processing Center (hereinafter referred as
CPC), vide intimation dated 05.12.2022, restricted the TDS credit
to Rs. 2,83,663/- citing mismatch with Form 26AS, without
providing adequate opportunity or basis for such adjustment.
2.1 Aggrieved, the Petitioner filed a rectification application
under Section 154 explaining that the entire interest income of Rs.
73,94,574/- was duly recorded in the books of M/s Ranka Dyeing
Mills, corresponding interest expenditure of Rs. 74,83,321/- was
accounted for, and only the net figure was reflected under
business income. Additionally, Rs. 6,47,842/- was disclosed under
“Income from Other Sources.” However, the CPC rejected the
rectification application on 04.10.2024.
2.2 The petitioner then preferred an appeal before the
Commissioner of Income Tax (Appeals) on 07.11.2024. Vide order
dated 04.12.2025 passed under Section 250, the appellate
authority allowed the appeal, accepted the Petitioner’s
reconciliation of interest income, and directed grant of full TDS
credit after verification with Form 26AS, along with consequential
relief. The findings adjudicated the issue of alleged mismatch and
treatment of interest income.
2.3 Notwithstanding, the respondents have issued a fresh notice
dated 23.03.2026 under Section 148 based on a sanction dated
20.03.2026, seeking to reopen the assessment on the ground of
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alleged escapement of income of Rs. 65,51,706/- based on the
same discrepancy flagged earlier on the Insight Portal.
2.4 Hence, the instant writ petition.
3. Mr. Sharad Kothari, learned counsel for the petitioner argues
that the impugned notice dated 23.03.2026 issued under Section
148 of the Income Tax Act, 1961, along with the sanction note
dated 20.03.2026, is ex facie illegal, arbitrary, and mechanical,
having been issued without proper application of mind to the facts
on record. The reopening is founded solely on a system-generated
flag under the “High Risk e-Verification” category on the Insight
Portal, alleging mismatch of interest income, while completely
disregarding that the entire interest income, as reflected in Form
26AS, had already been duly accounted for in the books and
disclosed in the return under the head “Business Income” after
netting off corresponding interest expenditure. It is further
contended that the Respondents failed to furnish the Petitioner
with the foundational material and verification reports relied upon,
thereby causing serious prejudice and violating principles of
natural justice.
3.1 It is further argued by learned counsel for the petitioner that
the impugned action is wholly without jurisdiction as it fails to
satisfy the mandatory requirement of existence of “information”
suggesting escapement of income within the meaning of Section
148. The term “information” necessarily connotes fresh, specific,
and tangible material coming into the possession of the Assessing
Officer subsequent to earlier proceedings. In the present case, the
entire basis of reopening is the very same alleged discrepancy
relating to interest income reflected in Form 26AS, which was
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already on record, duly explained, and conclusively adjudicated by
the appellate authority. No new material or independent input
under the scheme of Section 135A has been brought on record,
rendering the assumption of jurisdiction legally unsustainable.
3.2 Learned counsel further submits that the impugned notice is
nothing but a clear case of impermissible “change of opinion” on
identical facts and material that stood thoroughly examined and
decided in favour of the Petitioner by the Commissioner (Appeals)
vide order dated 04.12.2025. The Assessing Officer has sought to
reopen a concluded issue without any fresh tangible material,
which amounts to a review in the guise of reassessment–an
action not contemplated under the scheme of the Act. It is well
settled that reassessment proceedings cannot be initiated to re
appreciate or revisit the same material merely because a different
view is sought to be taken.
3.3 Lastly, it is contended by learned counsel for the petitioner
that the impugned proceedings are vitiated by borrowed
satisfaction and gross non-application of mind, as the Assessing
Officer has mechanically relied on system-generated data without
conducting any independent inquiry or appreciating the detailed
reconciliation already accepted in earlier proceedings. The
reopening, based on superficial comparison of figures in Form
26AS, ignores settled principles that taxation must be based on
real income and proper accounting treatment. The repeated
initiation of proceedings on the same grounds, despite a binding
appellate order, constitutes a colourable exercise of power, is
contrary to judicial discipline, and renders the impugned notice
liable to be quashed.
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4. Mr. Sunil Bhandari, learned counsel for the respondents, on
the other hand opposes the petition urging that not only the same
has been filed prematurely without responding to the impugned
notice and but is an attempt to short circuit the statutory scheme
contained under the Income Tax Act.
4.1. He would further strenuously argue that in any case, the
contention that the show cause notice has been issued without
any additional information is belied by the very bare reading of the
sanction note dated 20.03.2026, which would reveal that it is
based on the cogent information which was found to be prima
facie believe worthy upon due application of mind which led the
competent authority to issue the impugned show cause notice.
Any argument to the contrary is thus, untenable and has to be
necessarily rejected by this Court and the writ petition accordingly
deserves to be dismissed at the very threshold.
5. In the aforesaid backdrop, we have heard the rival
contentions of the learned counsels representing the respective
parties and have perused the material available before us. We
shall now proceed to render our opinion qua the same by
recording reasons and discussion thereof in the succeeding part of
the instant order.
6. Before examining the merits of the contentions, it is
necessary to refer to the sanction note dated 20.03.2026, which
sets out the reasons for issuing the impugned notice dated
23.03.2026 under Section 148 of the Income Tax Act, 1961,
proposing reassessment for Assessment Year 2022-23.
7. At this stage, it may be noted that the assessee had filed an
appeal against the original assessment for the said year, which
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was disposed of by the Commissioner of Income Tax (Appeals)
vide order dated 04.12.2025, and that order has since attained
finality.
8. Reverting to the sanction note dated 20.03.2026 and the
notice dated 23.03.2026 issued under Section 148, same are
reproduced below for ready reference :-
“Sanction Note dated 20.03.2026
In this case information has been made available to this office through
Insight Portal under the head High Risk e-Verification’, the scheme
notified under Section 135A by the Hon’ble CBDT vide Notification
No. 137/2021/F. No. 370142/57/2021TPL (Part-1) dated 13.12.2021
notifying the e-Verification Scheme, 2021.
2. Vide aforementioned Notification, the Central Government has
notified the e-Verification Scheme, 2021 in accordance with the
provisions of Section 135A of the Income tax Act, 1961. Accordingly,
High Risk Cases related to Assessment Year 2022-23 have been
verified by the Prescribed Authority under the scheme and submitted a
Preliminary Verification Report (PVR) estimating the Income
Escapement. As per Clause 4(9) of the e-Verification Scheme-2021,
matched the Preliminary Verification Report with the latest Income Tax
Return to prepare the Final Verification Report (FVR) wherein Value at
Risk (VaR) has been arrived. Which is mentioned as under:-
3. In the instant case notices u/s 133(6) were issued to verify the
interest from deposits at Rs.71,99,135/ and the interest from savings
bank at Rs. 73/
In response to the notice issued assessee has filed its submission and
stated that “It Has Already Been Considered While Filing the Return.
3.1 The reply of the assessee is considered after duly examination of
ITR which is placed on record.
3.2 To verify the facts of the case it is seen from the ITR that the
assessee has disclosed interest income of Rs. 6,47,842/- (including
interest from deposit of Rs. 6,47,429/- and interest from saving bank of
Rs. 313/-) during the F.Y.2021-22 offering income under income from
other sources. The relevant portion of the ITR is being reproduced as
under:
B4 Income From Other B4 6,47,842
Source
Note-Fill "Sch
TDS2" if applicable
S.No. Nature of Income Description (If any Total Amount
other selected)
1. Interest from Saving Interest from Saving 313
Bank Account
2. Any Other Interest (Others) 6,47,429
3. Any Other Other Income 1003.3 From the above, it can be inferred that the assessee has shown an
amount of only Rs.6,47,429/- against Rs. 71,99,135/- on account of(Uploaded on 07/05/2026 at 02:18:55 PM)
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[2026:RJ-JD:20594-DB] (7 of 13) [CW-8724/2026]interest from deposits and a separate amount of Rs. 313/- as interest
from savings bank which is more than the amount i.e., Rs. 73 which is
subject to verification.
3.4 As the assessee has disclosed interest from savings bank of Rs.
313/- in its ITR for AY 2022-23 which is more than the amount under
verification, hence no adverse inference is drawn on the issue.
3.5 Further in absence of any satisfactory explanation from the
assessee with regards to the amount under verification on account of
interest received from deposits the balance amount of Rs. 65,51,706/-
(Rs. 71,99,135/- Rs. 6,47,429/-) cannot be verified. Further, though it
is seen that the assessee has shown business receipts of Rs. 29,94,300/-
and offered income of Rs. 3,27,245/- under provisions of section 44AD
of the Income Tax Act, 1961, no credit of such receipts can be given in
the absence of any explanation from the assessee with regards to the
nature of business and receipts received by the assessee during the FY
2021-22.
3.6 Having regard to the above, and in view of the absence of
satisfactory explanation with regards to the interest from deposits
received during the relevant year, there seems to be an escapement of
income of Rs. 65,51,706/- on account of interest from deposits in the
hands of the assessee and remained unexplained and the same has
escaped assessment within the meaning of section 147 of the Act.
4. In view of the above facts and circumstances there is information
within the meaning of Clause (iv) of sub section (3) of section 148 of
the I.T. Act, 1961 which suggest that income chargeable to tax as
discussed above has escaped assessment for Assessment Year 2022-23
and accordingly it is fit case for issuance of notice under section 148.
Further, in view of section 148A(4) of the I.T. Act proceeding under
section 148A are not required.
Notice Dated 23.03.2026
1. I have received information under the scheme notified u/s 135A that
income chargeable to tax has escaped assessment for the Assessment
Year under consideration in your case/the case of the person in respect
of which you are assessable under Income-tax Act, 1961.
2. 1, therefore, propose to assess or reassess such income or recompute
the loss or the depreciation allowance or any other allowance or
deduction for the Assessment Year 2022-23 and I, hereby, require you
to furnish, within a period of 90 days in which this notice is issued, a
return in the prescribed form for the Assessment Year 2022-23.
3. This notice in being issued after obtaining the prior approval of the
specified authority accorded on date 20-MAR-26 vide Reference No.
100000090968176.”
9. As already mentioned, after the completion of the original
assessment proceedings, the assessee preferred an appeal before
the Commissioner of Income Tax (Appeals). We find that the
CIT(A), upon due examination of the same material on record, as
noted in the sanction note, ibid, adjudicated the matter on merits.
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No fresh material or new information has since come into the
possession of the Assessing Officer that can possibly justify
reopening the assessment on the ground of alleged escapement of
income. Issuance of the impugned show cause notice in the
present case is, at best, one of a mere change of opinion by an
assessing officer, which does not constitute a valid ground for
reassessment. Let us see how.
10. CIT order be seen at this stage, relevant extract thereof is
reproduced hereinbelow:-
“5. Findings & Decision
5.1. I have carefully considered the grounds of appeal, the material
available on record, the rectification order passed under section 154
of the Act, the intimation issued under section 143(1) of the Act, and
the submissions tendered by the Appellant. The primary issue for
adjudication is whether the AO, CPC was justified in restricting the
TDS credit to Rs.2,83,663/- as against the claim of Rs.7,15,391/-
made in the return of income, and whether the subsequent
rectification applications filed by the Appellant warranted
acceptance under section 154 of the Act.
5.2. It is noted from the return and accompanying financials that the
Appellant had disclosed substantial interest transactions during the
relevant year. Interest income of Rs. 73.94.574/- was recorded in the
business accounts after netting off interest expenditure, and a
further sum of Rs.6.47,842/- was separately declared as income
from other sources. The totality of interest income was thus stated to
have been duly offered to tax under the relevant heads. The TDS
reflected in Form 26AS/AIS corresponds to such interest receipts.
The Appellant’s contention is that the gross interest income
corresponding to the TDS has in fact been declared in the ITR,
albeit partly under business income after netting and partly under
income from other sources.
5.3. The intimation issued under section 143(1) of the Act restricted
the TDS credit on the ground that the income relating to such TDS
was not fully reflected in the return. However, the intimation does
not set out any detailed computation or reason as to how the figure
of Rs.2.83.663/- was arrived at. Further, during rectification
proceedings under section 154 of the Act, no specific mismatch or
unreported income was pointed out by AO, CPC, nor was any
material furnished to demonstrate that the interest income subject to
TDS was not accounted for in the returned income. The Appellant’s
repeated rectification applications thus remained unaddressed on
merits, which has resulted in the continuation of an adjustment
whose basis is not clearly discernible from the record.
5.4. It is a settled position that an adjustment under section 143(1)
(a) of the Act must be confined strictly to matters apparent from the
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[2026:RJ-JD:20594-DB] (9 of 13) [CW-8724/2026]for invoking section 154 of the Act, the error must be apparent from
the record. In the present case, the AO, CPC has not demonstrated
that there existed any non-disclosure of income relating to TDS
which would justify restricting the TDS credit. On the contrary, the
financial statements and computation furnished by the Appellant
prima facie reflect that the underlying interest income was indeed
included in the return, either as business income or income from
other sources. The non-consideration of this aspect, despite specific
rectification petitions filed by the Appellant, constitutes a mistake
apparent from the record.
5.5. It is further observed that Form 26AS fully reflects the
Appellant’s entitlement to TDS credits claimed in the return. If the
AO, CPC considered that any portion of Income corresponding to
the TDS was not disclosed, it was incumbent on the AO, CPC to
specify the precise mismatch, quantify the undisclosed amount, and
provide reasoning. The absence of such disclosure renders the
restriction of TDS credit unsustainable. The consistent explanation
of the Appellant that the interest income Was duly declared has not
been rebutted with any contrary evidence. In the absence of such
rebuttal, and in view of the materials available, the restriction of
TDS credit appears to have been mechanically applied and not in
accordance with law.
5.6. Accordingly, I find that the reduction of TDS credit from
Rs.6,34,840/- to Rs.2,83,663/- in the intimation under section 143(1)
of the Act is erroneous. The resulting denial of TDS credit to the
extent of Rs.3,51,177/- is not supported by reasons or by any
demonstrable mismatch in income. The denial of rectification is
therefore not in accordance with section 154 of the Act. The
Appellant is entitled to the full TDS credit as claimed in the return,
subject to verification of matching PAN- based credits in Form
26AS”.
11. The contents of the sanction note leading to issuance of the
fresh notice for reassessment, when read in conjunction with and
compared against the order dated 04.12.2025 passed by the
CIT(Appeals), do nothing more than reveal a change of opinion on
the part of the Assessing Officer with respect to facts and
materials that had already been examined and conclusively
adjudicated by a competent appellate authority. The sanction note
raises no fresh ground, discloses no new material, and advances
no tangible information beyond what was already on record before
the CIT(Appeals). It is, therefore, nothing but an attempt to
reopen a concluded matter on the basis of a revisited view of the
same facts, a course of action that is wholly impermissible in law.
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12. Dehors our discussion in the preceding part, even otherwise,
the order passed by the CIT(A) is legally and factually well-
grounded. The core issue before the CIT(A) was the arbitrary
restriction of TDS credit to Rs. 2,83,663/- against the assessee’s
legitimate claim of Rs. 7,15,391/-, without any computation,
reasoning, or identification of a specific mismatch in the intimation
issued under Section 143(1). The CIT(A) correctly held that such
an adjustment, being a summary proceeding confined strictly to
errors apparent from the return, cannot be sustained in the
absence of any demonstrable basis.
12.1. On the question of disclosure, the CIT(A) rightly noted that
the assessee had not suppressed any income. Interest income of
Rs. 73,94,574/- was recorded in the business accounts after
netting against interest expenditure, and a further Rs. 6,47,842/-
was declared under income from other sources. The totality of
interest income was thus offered to tax, albeit across different
heads, a fact the AO (CPC) failed to appreciate before
mechanically restricting the TDS credit.
12.2. The CIT(A) further correctly held that the assessee’s
repeated rectification applications under Section 154 were left
unaddressed on merits, despite being supported by Form 26AS,
financial statements, and detailed computation. The failure of the
AO (CPC) to either accept or rebut these applications with contrary
evidence itself constitutes a mistake apparent from the record,
warranting correction.
13. Moreover, adverting once again to the core issue of change of
opinion being the cause of reassessment, the findings of CIT order
assume decisive significance in the context of the impugned notice
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[2026:RJ-JD:20594-DB] (11 of 13) [CW-8724/2026]
dated 23.03.2026 under Section 148. The sanction note proceeds
on the premise that interest income from deposits remains
unexplained and has escaped assessment. However, the CIT(A)’s
order, which has attained finality, not having been challenged by
the Revenue, conclusively establishes that the income was duly
disclosed and the denial of TDS credit was erroneous.
14. There exists, therefore, no fresh information suggesting
escapement of income within the meaning of Section 148. The
Assessing Officer is seeking to reopen an assessment on a premise
already negated by a binding appellate order, which amounts to a
collateral attack on a final adjudication and is wholly impermissible
in law.
15. It is a firmly settled position of law that the power of
reassessment conferred under Section 147 of the Income Tax Act,
1961 cannot be exercised merely on the basis of a change of
opinion by the Assessing Officer with respect to facts and
materials that were already available on record at the time of the
original assessment.
16. Reassessment is not a second innings for the Assessing
Officer to reconsider or re-appreciate evidence that was already
before him. If the Assessing Officer forms an opinion on a
particular issue during the original assessment, whether expressly
or by necessary implication, any subsequent attempt to reopen
the assessment on the same facts constitutes nothing more than a
change of opinion, which is not a valid jurisdictional ground for
invoking Section 147.
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17. Hon’ble the Supreme Court in CIT v. Kelvinator of India
Ltd.1 authoritatively settled this position by holding that although
the Finance Act, 1989 omitted the requirement of “reason to
believe” based on “new tangible material”, the concept of “change
of opinion” as a bar to reassessment continues to operate as an
in-built check against arbitrary exercise of the power. It is held
therein that the Assessing Officer must have tangible material to
conclude that income has escaped assessment and that mere re-
examination of the same facts cannot justify reopening.
18. This principle has also been consistently affirmed by various
High Courts. Delhi High Court in CIT v. Eicher Ltd.2 reiterated
that where the original assessment was completed after due
application of mind to the material on record, issuance of a
reassessment notice on the same material is impermissible.
Similarly, Gujarat High Court in Praful Chunilal Patel v. M.J.
Makwana3 held that reopening based on information already
available during original assessment proceedings amounts to a
change of opinion and is liable to be quashed. Qua the ratio
enunciated by both the High Courts, ibid, we need add no more,
other than simply observe that we are in respectful agreement
with the same.
19. In the present case, the interest income from deposits and
the manner of its disclosure in the return were matters already
examined, and conclusively adjudicated, by the CIT(A) in its order
dated 04.12.2025. No new or fresh material has come to light
thereafter. The sanction note dated 20.03.2026 draws upon the
1. (2010) 320 ITR 561 (SC)
2. (2007) 294 ITR 310 (Del)
3. (1994) 236 ITR 832 (Guj.)
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very same figures and information that were before the appellate
authority. The reassessment notice dated 23.03.2026 is therefore
nothing but a re-examination of a concluded matter, squarely
falling within the prohibited category of a change of opinion. It is
accordingly held to be without jurisdiction and liable to be
quashed.
20. In view of the aforesaid, we are of the opinion that the
appellate order having attained finality, the subsequent notice
dated 23.03.2026 issued under Section 148 of the Income Tax
Act, 1961 for reopening the assessment, on the basis of same
facts and material, is clearly beyond the jurisdiction of the
Assessing Officer and constitutes an overreach of authority. The
very issue has already been examined and adjudicated by the
quasi-judicial authority, i.e., the Commissioner of Income Tax
(Appeals), and therefore cannot be reopened on the same set of
facts. The action of the Assessing Officer in seeking to revisit the
concluded matter amounts to exceeding his authority and reflects
an improper exercise of power.
21. The writ petition is accordingly allowed. Both i.e. the notice
dated 23.03.2026 issued under Section 148 of Income Tax Act,
1961 (Annexure-2) and sanction note dated 20.03.2026 and all
other consequential proceedings arising therefrom are set aside.
22. All pending applications including stay application also stand
disposed of.
(SANDEEP SHAH),J (ARUN MONGA),J
53-raksha/-
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