The assessee sought to challenge the notice issued under section 148 by JAO on grounds that it was without jurisdiction, void ab initio and in contravention of the statutory scheme under section 151A. The High Court rejected the contentions of the assessee that other High Courts had held that such notice issued was invalid; the Supreme Court had dismissed SLP against such orders and hence, by necessary implication, read down the judgment in the case of TKS Builders [2024] 469 ITR 657 (Delhi)(HC). The High Court held that the Supreme Court has only dismissed the SLP without dealing with the issue, and the SLP preferred against TKS Builders (supra) was still pending adjudication before the Supreme Court, as well as not stayed the effect of the orders passed in the writ petitions based on the judgment in the case of TKS Builders (supra). Hence, the High Court dismissed the petition following the judgment in the case of TKS Builders (supra) wherein it was held that JAO and FAO possess concurrent jurisdiction to initiate reassessment proceedings.