The Telangana and Madras High Courts have reportedly reserved their verdicts in matters concerning the constitutional validity of Section 147A of the Income-tax Act, 1961, and the authority of Jurisdictional Assessing Officers (JAOs) to initiate reassessment proceedings under the faceless tax regime.
According to a courtroom update shared by Krishna Mayaramka, the respective benches reserved orders after extensive arguments by Additional Solicitor General N. Venkataraman, representing the Revenue, and senior counsel appearing for the petitioners. The update also states that the Karnataka High Court is expected to pronounce its judgment on October 5, 2026. Official orders confirming these latest developments were not available in the sources reviewed.
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Telangana Bench Seeks Update on Other High Court Proceedings
According to the courtroom account, the Telangana High Court asked whether any other High Court had delivered a final judgment on the issue. In response, ASG N. Venkataraman reportedly informed the bench about the Karnataka High Court’s scheduled pronouncement on October 5.
The account indicates that verdicts from Telangana and Madras are now awaited, but does not specify their pronouncement dates.
What Does Section 147A Provide?
Parliament inserted Section 147A through the Finance Act, 2026, with retrospective effect from April 1, 2021. The provision addresses the identity of the Assessing Officer authorised to act for the purposes of Sections 148 and 148A.
It provides that the Assessing Officer for these purposes means an officer other than the National Faceless Assessment Centre or an assessment unit referred to in Section 144B(3). It expressly operates notwithstanding court judgments, Section 151A, or any scheme framed under that section.
The distinction is significant: Section 147A concerns the authority responsible for the specified reassessment steps, while Sections 148 and 148A govern the notices and preliminary proceedings at the centre of the dispute.
Why the JAO–FAO Issue Matters
The controversy concerns whether a taxpayer’s jurisdictional officer could independently issue reassessment notices under Section 148 and pass orders under Section 148A, or whether those functions had to be performed through the prescribed faceless mechanism.
Different High Courts had taken differing views on this question. The retrospective insertion of Section 147A sought to clarify the authority of jurisdictional officers, giving rise to a further challenge over the validity and effect of that legislative intervention.
The litigation therefore extends beyond the choice of officer issuing a notice. It also concerns whether the retrospective amendment validly addresses the legal defects identified in earlier judgments.
Punjab and Haryana High Court Ruling Under Challenge
The Punjab and Haryana High Court had struck down Section 147A in a judgment delivered on September 10, 2026.
As reported, the High Court concluded that the retrospective provision failed to remove the underlying defect identified in earlier rulings, particularly because Section 151A and the faceless allocation scheme dated March 29, 2022, continued to exist without amendment. The batch involved more than 500 writ petitions.
The Union Government subsequently challenged that decision before the Supreme Court.
Supreme Court Stay Comes With a Condition
On September 18, 2026, a Supreme Court bench comprising Justice J.B. Pardiwala and Justice K. Vinod Chandran stayed the Punjab and Haryana High Court judgment pending final disposal of the Centre’s challenge.
The stay was conditional: the Court directed that the assessment proceedings should not proceed further until final disposal of the main matter. It scheduled the case for final hearing on December 3, 2026. The interim order therefore does not amount to a final ruling upholding the constitutional validity of Section 147A.
Further Verdicts Awaited
The reported reservation of verdicts by the Telangana and Madras High Courts places renewed attention on the treatment of JAO-issued reassessment notices and the retrospective operation of Section 147A.
The Karnataka High Court’s reported October 5 pronouncement is the next development identified in the courtroom update. However, reserving judgment does not indicate whether a court will uphold or strike down the provision.
The supplied update also refers to more than ₹20 lakh crore and approximately 8.5 lakh reassessment notices being at stake. Those figures could not be independently verified from official material reviewed and should be treated as claims in the update, rather than established tax exposure.
With further High Court decisions awaited and the Supreme Court hearing scheduled for December 3, the dispute over reassessment jurisdiction and retrospective validation remains unresolved.
