Bombay High Court Grants Interim Stay on Reassessment Notice Amidst Constitutional Challenge to Sections 148 and 148A

Overview of the Dispute

In a significant judicial development, the Bombay High Court has taken up a critical writ petition in the matter of G M Polyplast Ltd. Vs ACIT. The core of the litigation revolves around a reassessment notice issued to the assessee by the revenue authorities. The contested notice, dated 30 March 2025, was invoked under Section 148 of the Income-tax Act.

The assessee approached the High Court not merely to quash the individual notice, but to challenge the very statutory foundation upon which the revenue department based its reassessment actions.

The writ petition filed by the assessee mounts a substantial constitutional challenge against specific provisions introduced or modified in the reassessment regime. The primary legal contentions include: