Tax liability notice treated under the Act, with fresh determination required and issues rendered academic.

The impugned notice was treated as a notice under the Act, and the Assessing Authority was required to determine the petitioners' tax liability afresh under the law as applicable at the relevant time. In light of the Supreme Court decision relied upon, the issues raised became academic, and the writ petitions were disposed of without any substantive adjudication on the merits.

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Outcome: The writ petitions were disposed of after the parties agreed that the impugned notice would be treated as a notice under the Act and that the Assessing Authority would determine the petitioners' tax liability afresh under the law as applicable at the relevant time. In view of the Supreme Court decision relied upon, the questions raised were treated as having become academic and no substantive adjudication was recorded.

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