Ramchand Raimalani’s three tax writs were revived by court

Ramchand Murlidhar Raimalani’s three challenges to reassessment notices were restored by the High Court of Judicature at Bombay on July 20, 2026 after Supreme Court orders set aside the Hexaware Technologies Ltd. Vs ACIT decision. The notices allege unaccounted transactions totalling Rs 29.07155 lakh across assessment years 2021-22 to 2023-24.

Why were Ramchand Raimalani’s three tax writs revived?

Ramchand Raimalani’s three tax writs were revived because the January 19, 2026 disposal orders expressly allowed the Income Tax Department to seek revival if the Supreme Court set aside Hexaware Technologies Ltd. Vs ACIT. The Supreme Court set aside that decision through orders dated April 10, 2026 and May 4, 2026, removing the precedent on which the High Court had disposed of the petitions.

Ramchand Raimalani filed Writ Petition Nos. 249, 250 and 252 of 2025 on December 4, 2025 against the Assistant Commissioner of Income Tax, Circle 19(3), and the Union of India. Each petition challenged a reassessment notice issued under Section 148 of the Income-tax Act, 1961, a provision used where the department considers income chargeable to tax to have escaped assessment.

The High Court had set aside the three Section 148 notices and proceedings arising from them on January 19, 2026, relying on Hexaware. After the two Supreme Court orders, the department issued a July 10, 2026 notice informing Ramchand Raimalani that restoration or revival was scheduled. The High Court then restored the petitions on July 20, 2026 with connected income-tax matters, and the disclosure records all three as pending.

What notices did Ramchand Raimalani challenge?

Ramchand Raimalani challenged three notices issued by a Jurisdictional Assessing Officer, or JAO, under Section 148 for assessment years 2021-22, 2022-23 and 2023-24. The notices for the first two years are dated March 29, 2025, while the notice for assessment year 2023-24 is dated March 31, 2025.

The writ-petition descriptions say the notices were based on a search operation at M/s. J.P. Exports and alleged unaccounted transactions. The alleged amount for assessment year 2021-22 was Rs 12.27488 lakh, compared with Rs 7.07853 lakh for assessment year 2022-23 and Rs 9.71814 lakh for assessment year 2023-24. The three notices therefore total Rs 29.07155 lakh, with the 2021-22 amount representing the largest single allegation.

The notices required Ramchand Raimalani to address reassessment proceedings rather than recording a final tax finding. The prospectus describes the amounts as allegations in the notices and does not disclose a final High Court ruling on the underlying transactions, a final reassessment order for these notices, or a final demand resulting from the three writ-petition matters.

What was Ramchand Raimalani’s Hexaware jurisdiction argument?

Ramchand Raimalani argued that the Section 148 notices were issued without jurisdiction because they came from a JAO rather than a Faceless Assessing Officer, or FAO. The petitions relied on Hexaware Technologies Ltd. Vs ACIT for the proposition that an FAO, not a JAO, had authority to issue such notices within the faceless assessment framework.

The requested remedies in each December 4, 2025 petition included quashing the relevant notice, directing the respondents to withdraw it, preventing coercive action and staying its operation pending disposal. The January 19, 2026 High Court orders set aside the notices and consequential proceedings, but did so with the department’s right to seek revival if Hexaware was overturned by the Supreme Court.

The restored matters are not the same as a final decision in favour of either side. The July 20, 2026 restoration order directed the Income Tax Department to file an affidavit-in-reply in the lead petition, with that affidavit to serve as the response in all connected petitions. On July 30, 2026, the High Court gave Ramchand Raimalani additional time to reconstruct petition records where required and to make amendments.

How do the revived writs fit Ramchand Raimalani’s other tax matters?

The revived writs sit alongside, but should be distinguished from, separately disclosed reassessment proceedings for the same three assessment years. In the litigation filed against Ramchand Raimalani, the prospectus says notices dated March 29, 2025 for assessment years 2021-22 and 2022-23, and March 31, 2025 for assessment year 2023-24, were based on information obtained through a Section 132 search and seizure operation involving the OJS Group, also called Operation Jewel Star.

For the OJS Group-related proceedings, Ramchand Raimalani filed returns on May 6, 2025. The Income Tax Department subsequently issued notices dated June 25, 2025 under Section 143(2) read with Section 147, followed by requests for information and documents dated August 4, 2025 under Section 142(1). Section 143(2) is a scrutiny notice, while Section 142(1) enables the department to seek information or supporting documents.

The disclosure identifies M/s. J.P. Exports as the search basis in the three writ-petition descriptions, while it identifies the OJS Group search as the basis in the separate proceedings summary. For assessment year 2023-24, both descriptions state Rs 9.71814 lakh, although one refers to alleged unaccounted transactions and the other to alleged escaped income. The prospectus does not state that the J.P. Exports search and the OJS Group search are the same matter.

Ramchand Raimalani also has tax matters outside the three revived writs. For assessment year 2012-13, a December 6, 2019 reassessment order added Rs 40.42487 lakh for alleged income from Client Code Modification transactions, and a March 19, 2022 penalty order imposed Rs 12.49437 lakh. For assessment year 2025-26, the National Faceless Assessment Centre assigned his scrutiny assessment under Section 144B on June 20, 2026, followed by a Section 142(1) notice dated August 7, 2026.

Conclusion

Ramchand Raimalani’s three writ petitions returned to pending status because their January 19, 2026 disposal was conditional on the continued validity of Hexaware, which the Supreme Court set aside on April 10 and May 4, 2026. The revived challenges concern three Section 148 notices alleging Rs 29.07155 lakh of unaccounted transactions, but neither the allegations nor the jurisdiction objections have been finally determined in the disclosed proceedings.

The next disclosed procedural steps are the department’s affidavit-in-reply in the lead petition and Ramchand Raimalani’s reconstruction of records or amendments permitted on July 30, 2026. The High Court’s consideration of the revived petitions on their merits, under the legal position following the Supreme Court orders, will determine whether the notices remain subject to challenge or the reassessment process advances.