A coordinate-bench ruling on identical reassessment facts governs the taxpayer’s subsequent-year challenge.

The petitioner challenged an order dated 30 June 2026 under Section 148A(3) of the Income-tax Act, 1961, and the consequential notice under Section 148 for AY 2020–21.

The proceedings concerned information alleging that the petitioner was involved in transactions with an insurance company through middle-layer business entities. The petitioner argued that the amount identified had been disclosed as brokerage income and that the transaction was genuine.

The Revenue submitted that the High Court had dismissed the petitioner’s earlier writ petition concerning an almost identical notice for AY 2019–20. The petitioner relied on an interim order in T.S.G. International Marketing Private Limited.

Whether the petitioner’s challenge to the Section 148A(3) order and Section 148 notice for AY 2020–21 should be entertained when its challenge concerning materially identical information for AY 2019–20 had been dismissed.

Whether the Court should depart from the decision in the petitioner’s earlier case in light of the petitioner’s reliance on T.S.G. International Marketing Private Limited.

Sections 148A(3) and 148 of the Income-tax Act, 1961 provide the statutory basis for the order determining whether it is a fit case to issue a reassessment notice and for issuance of that notice.

The Court applied the principle of judicial discipline that a Coordinate Bench should not take a different view from the one adopted by another Coordinate Bench in the same petitioner’s case on materially identical facts, absent a basis to do so.

The Court also noted that the order in T.S.G. International Marketing Private Limited relied upon by the petitioner was interim, whereas the decision in the petitioner’s earlier case was final.

The Court found that, apart from the assessment year, the facts were identical to those in the petitioner’s earlier challenge, which had been dismissed.

It therefore considered itself bound by judicial discipline to follow that decision. The interim order in T.S.G. International Marketing Private Limited did not warrant a different result, and the Court did not independently revisit the merits of the reassessment proceedings.

The pending applications were also disposed of.