The Hon’ble Punjab and Haryana High Court (HC) in Jyoti Sareen vs. UOI & Others (CWP No. 15791-2024 (O&M)) (Order) held the retrospective amendments carried out vide the Finance Act, 2026, with respect to the powers of the Jurisdictional Assessing Officer (JAO) to issue a reopening notice under section 148 (Reopening Notice) of the Income-tax Act, 1961 (IT Act), as unconstitutional, being violative of the ‘doctrine of separation of powers’ and thus violative of Article 14 of the Constitution of India.