Supreme Court to hear challenge on tax reassessment notices after high court strike down

On Wednesday, the Supreme Court scheduled a hearing on the Centre’s appeal against a Punjab and Haryana High Court judgment that struck down Section 147A of the Income-Tax Act. The disputed provision aimed to confirm that regular jurisdictional assessing officers could issue reassessment notices, even though the faceless assessment scheme assigns cases electronically. The high court ruled the amendment unconstitutional, saying it attempted to retroactively validate a procedure previously found defective.

The matter had previously been sent back to high courts after Parliament introduced the amendment through the Finance Act, 2026. The Supreme Court will now decide whether Section 147A can protect reassessment actions by regular officers and whether its retrospective effect is permissible. The decision could reshape how the tax department reopens past assessments across India.