Reassessment Matters Remanded After Retrospective Amendment

The Karnataka High Court disposed of a batch of 70 writ appeals concerning reassessment notices issued under Sections 148 and 148A of the Income-tax Act, 1961, in light of a subsequent Supreme Court ruling addressing the retrospective insertion of Section 147A by the Finance Act, 2026. 

Since the Single Judges had earlier quashed reassessment proceedings primarily on the ground that Jurisdictional Assessing Officers (JAOs) lacked authority to initiate such proceedings, the Supreme Court's subsequent clarification and legislative amendment altered the legal foundation of those decisions. 

Consequently, the High Court remitted the matters for fresh adjudication, while preserving the assessees' right to challenge the validity, retrospectivity, scope, and applicability of the newly inserted Section 147A and other connected provisions.