Coordinate benches must follow prior rulings where reopening challenges involve identical facts.

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, concerning assessment year 2021–22.

The Revenue submitted that the petitioner’s challenge to an almost identical notice for assessment year 2019–20 had already been dismissed by a Coordinate Bench.

The petitioner accepted the similarity of the allegations but argued that the earlier decision had not properly considered an interim order in T S G International Marketing Private Limited v. Income Tax Officer, Ward 25(3), Delhi, W.P.(C) 9715/2025.

Whether the Court should interfere with the Section 148A(3) order and Section 148 notice for assessment year 2021–22, given the Coordinate Bench’s dismissal of the petitioner’s challenge concerning an almost identical notice for assessment year 2019–20.

Whether the interim order in T S G International Marketing Private Limited warranted a different result from the final decision in the petitioner’s earlier case.

The Court applied the principle of judicial discipline, holding that it should not take a view different from that taken by a Coordinate Bench in the petitioner’s own case where the material facts are identical.

Sections 148A(3) and 148 of the Income-tax Act, 1961, were the provisions under which the challenged order and notice had been issued.

The Court also noted the Revenue’s distinction that the order in T S G International Marketing Private Limited was interim, whereas the petitioner’s earlier case had resulted in a final decision.

The Court found that, apart from the assessment year, the facts were identical to those in the petitioner’s earlier case.

It therefore considered itself bound by the Coordinate Bench’s decision and declined to revisit the merits of the challenge.

The petitioner’s reliance on T S G International Marketing Private Limited did not alter that conclusion, as the cited order was interim, unlike the final judgment in the petitioner’s own earlier case.

The present decision accordingly rests on judicial discipline and the similarity of the cases, rather than an independent determination of whether income had escaped assessment.

The pending applications were also disposed of.