This compilation indexes twelve High Court rulings — from the Telangana, Gujarat, Calcutta, and Karnataka High Courts — in which assessees challenged orders passed under Section 148A(3) of the Income Tax Act, 1961, along with consequent notices issued under Section 148. The rulings span December 2025 through August 2026 and were sourced from the TaxNoticeAI structured legal corpus. This index is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who require a structured, court-wise reference point for Section 148A(3) litigation trends.

Disclaimer: This page is a research index only. Nothing on this page constitutes legal or tax advice. Readers must consult the full text of each judgment and seek qualified professional counsel before relying on any ruling.

The statutory framework in one paragraph

Section 148A of the Income Tax Act, 1961, inserted by the Finance Act 2021, lays down a pre-notice inquiry procedure before reassessment proceedings can be initiated. Under Section 148A(1), the Assessing Officer is required to conduct an inquiry and provide the assessee with an opportunity to be heard by issuing a show-cause notice. After considering the assessee's reply, the Assessing Officer is required under Section 148A(3) to pass an order determining whether it is a fit case for issue of a notice under Section 148. The order under Section 148A(3), along with the consequent notice under Section 148, has been the subject of extensive writ litigation in various High Courts, with assessees challenging these orders on grounds including procedural non-compliance, limitation, absence of new tangible information, and change of opinion.

The 12 rulings

1. Nitin Enterprises vs Income-Tax Officer Ward - 5(1)

Bench: Telangana High Court
Date: 11 August 2026
Sections engaged: 132, 143(1), 148, 148A, 148A(1), 148A(3), 151, 152(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner, a partnership firm engaged in trading in electrical fittings and retail at Hyderabad, filed a writ petition under Article 226 of the Constitution of India before the Telangana High Court. Per the source preview, the Jurisdictional Assessing Officer issued a show-cause notice dated 26.03.2026 under Section 148A(1) of the Act for the assessment year 2024-25, thereafter passed an order dated 24.06.2026 under Section 148A(3) of the Act, and consequently issued a notice under Section 148 of the Act on the same date; the Joint Commissioner of Income Tax was alleged to be the specified authority under Section 151 of the Act.

2. Pradipkumar Vallabhdas Joisar vs Income Tax Officer Ward 1 (3) (1)

Bench: Gujarat High Court
Date: 16 July 2026
Sections engaged: 148A(1), 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 9514 of 2026 before the Gujarat High Court at Ahmedabad, challenging proceedings under Sections 148A(1) and 148A(3). Per the source preview, the court noted that the controversy arising in the petition was in narrow compass and, with the consent of the advocates for both parties, the matter was taken up for hearing on the same day.

3. Rahul Kumar Shaw vs Union Of India And Ors

Bench: Calcutta High Court
Date: 12 June 2026
Sections engaged: 148, 149(1), 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WPO/909/2025) before the Calcutta High Court challenged the legality, validity, and sustainability of a notice under Section 148 of the Act along with an order passed under Section 148A(3) dated 30th June 2025 by the Income Tax Officer for Assessment Year 2020-21. The core issues raised by the petitioner were whether the notice under Section 148 for Assessment Year 2020-21 was barred by limitation under Section 149(1) of the Act, and whether it could be saved by the extended limitation period on the ground that the income escaping assessment amounts to or is likely to amount to Rs. 50,00,000/- or more.

4. O3 Developers Pvt. Ltd vs Income Tax Officer, Ward 3(1)(1)

Bench: Gujarat High Court
Date: 9 June 2026
Sections engaged: 148, 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 14096 of 2025 (heard together with R/Special Civil Application No. 14057 of 2025) before the Gujarat High Court at Ahmedabad, challenging proceedings under Sections 148 and 148A(3). Per the source preview, with the consent of the learned advocates appearing for the respective parties, the matter was taken up for final hearing by the court on that date.

5. Dhruv Vijaykumar Trivedi vs Deputy Commissioner Of Income Tax

Bench: Gujarat High Court
Date: 9 April 2026
Sections engaged: 148A(1), 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 4948 of 2026 before the Gujarat High Court at Ahmedabad, challenging proceedings under Sections 148A(1), 148A(3), and 148. Per the source preview, the matter was heard by the court as an oral judgment, with the petitioner represented by learned advocate and the respondent represented by the Senior Standing Counsel.

6. Deep Vijaykumar Trivedi vs Deputy Commissioner Of Income Tax

Bench: Gujarat High Court
Date: 7 April 2026
Sections engaged: 148A(1), 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 4515 of 2026 before the Gujarat High Court at Ahmedabad, challenging proceedings under Sections 148A(1), 148A(3), and 148. Per the source preview, the court noted the controversy was in narrow compass and, with the consent of the learned advocates for the respective parties, the matter was taken up for hearing on that date.

7. Gulbrandsen Private Limited vs Dy. Commissioner Of Income Tax, Circle

Bench: Gujarat High Court
Date: 24 February 2026
Sections engaged: 148A(3), 148A(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 15851 of 2025 before the Gujarat High Court at Ahmedabad, where the petitioner assailed a notice dated 16.06.2025 issued under a section of the Act (the source preview is truncated at that point). Per the source preview, since a short issue was involved in the present writ petition, the matter was taken up for final hearing with the consent of the learned advocates appearing for the respective parties.

8. Vijaykumar Jitendrakumar Trivedi vs Income Tax Officer, Ward 3(3)(5)

Bench: Gujarat High Court
Date: 10 February 2026
Sections engaged: 148A(1), 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 13093 of 2025 before the Gujarat High Court at Ahmedabad, challenging proceedings under Sections 148A(1) and 148A(3). Per the source preview, the court noted that the controversy arising in the petition was in narrow compass and, with the consent of the advocates for both parties, the matter was taken up for hearing on the same day.

9. Haldia Petrochemicals Limited vs Assistant Commissioner Of Income Tax

Bench: Calcutta High Court
Date: 20 January 2026
Sections engaged: 148A(1), 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WPO/753/2025) before the Calcutta High Court assailed reassessment proceedings initiated by a notice dated June 25, 2025 under Section 148 of the Act, preceded by an order dated June 25, 2025 passed under Section 148A(3), upon issuance of a show-cause notice dated March 19, 2025 under Section 148A(1), aimed at reassessing the petitioner's income for the assessment year 2019-20. Per the source preview, the show-cause notice referred to certain transactions allegedly conducted by one Padmey Impex Private Limited involving siphoning of funds from CC Accounts by using fake invoices/lorry receipts through several current accounts with banks including State Bank of India, ICICI, and Bank of Baroda, and alleged that the petitioner had also entered into transactions with the said entity.

10. Mark Steels Limited vs Assistant Commissioner Of Income Tax

Bench: Calcutta High Court
Date: 24 December 2025
Sections engaged: 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WPO 584 of 2025) before the Calcutta High Court sought to challenge an order passed under Section 148A(3) dated 26th June, 2025, as well as the notice issued under Section 148 in respect of the assessment year 2021-22, on the specific ground that the same are based on change of opinion. Per the source preview, the petitioner's senior counsel drew the court's attention to the notice under Section 148A(1) dated 11th March, 2025 and submitted that such notice was based on information uploaded in the Insight Portal of the Income Tax Department.

11. Infosys Bpo Poland Spzoo vs Assistant Commissioner

Bench: Karnataka High Court
Date: 11 December 2025
Sections engaged: 148A(3), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 30392 of 2025) was filed before the Karnataka High Court at Bengaluru under Article 226 of the Constitution of India, praying to quash an order dated 27.06.2025 bearing DIN ITBA/AST/F/148A/2025-26/1077927357(1) passed under Section 148A(3) of the Act for the assessment year 2019-20. Per the source preview, the petition came up for preliminary hearing and the court recorded an oral order on that date.

12. Hitarg Agritrade Commodities Pvt Ltd vs Income Tax Officer, Ward 1 (2)(3)

Bench: Gujarat High Court
Date: 9 December 2025
Sections engaged: 148, 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as R/Special Civil Application No. 12238 of 2025 (along with a Civil Application for Amendment) before the Gujarat High Court at Ahmedabad, challenging proceedings under Sections 148 and 148A(3). Per the source preview, since a short issue was involved in the present writ petition, the same was taken up for final hearing and disposal on that date with the Senior Standing Counsel waiving service of notice of rule on behalf of the respondents.

Patterns across these 12 rulings

Writ jurisdiction universally invoked: In all twelve cases across the source previews, assessees approached High Courts under Article 226 of the Constitution of India by way of Special Civil Applications or Writ Petitions, indicating that challenges to Section 148A(3) orders are consistently pursued through the constitutional writ route rather than through the statutory appellate hierarchy.
Concentration in Gujarat High Court: Eight of the twelve rulings originate from the Gujarat High Court at Ahmedabad. Several of these petitions share overlapping counsel appearances and were disposed of as oral judgments on the date of hearing, suggesting a high volume of Section 148A(3) litigation before that court during the 2025–2026 period.
Coupled challenge to Section 148 notices: In the majority of cases in this compilation, the petitioner challenged both the order under Section 148A(3) and the consequent notice under Section 148 together in the same writ petition, reflecting the practical reality that the two are typically issued simultaneously or within a short interval.
Limitation as a distinct ground of challenge: In at least one case in this compilation (Rahul Kumar Shaw vs Union Of India And Ors), the challenge specifically raised the question of whether the Section 148 notice was barred by limitation under Section 149(1), including the threshold condition relating to income escaping assessment of Rs. 50,00,000/- or more for the extended limitation period to apply.
Change of opinion as a ground: In at least one case in this compilation (Mark Steels Limited vs Assistant Commissioner Of Income Tax), the specific ground of challenge was that the Section 148A(3) order and the consequent Section 148 notice were based on change of opinion, with the petitioner pointing to information uploaded on the Insight Portal of the Income Tax Department as the alleged basis for the show-cause notice.

How to use this compilation

Researchers using this index as a starting point should verify each ruling against its full judgment text, obtainable from the official court portal of the respective High Court or from indiankanoon.org using the writ petition number indicated in the source preview. The source previews reproduced here are truncated and do not represent the complete reasoning or operative orders of the courts; outcome directions are not available from the source data for any of the twelve cases listed, and researchers should not assume a particular outcome without reading the full judgment.

When using this index for comparative analysis, researchers should note that many of these cases are at the stage of preliminary or final hearing on the writ petition and may have been subject to stays, modifications, appeals to a Division Bench, or further proceedings before the Supreme Court after the date of the order listed here. It is advisable to check whether any of these rulings have been appealed, stayed, or reversed before relying upon them as persuasive authority.

Researchers should additionally cross-reference applicable CBDT circulars, instructions, and notifications on reassessment procedure issued under Section 148A, as these may affect the procedural validity of notices and orders in any given assessment year. The section numbering under the Finance Act 2021 amendments should be verified carefully, as pre-amendment and post-amendment provisions governing reassessment carry different procedural requirements.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 148A(3) Income Tax Orders: 12 High Court Rulings (2025–2026)