Reassessment and rent arrears questions warrant larger Bench review where no binding precedent governs the issue.

Substantial and recurring questions concerning the taxability of arrears of rent, the scope of reassessment under sections 147 and 148, the four-year limitation, and the interaction between heads of income and income from house property required authoritative examination. In the absence of an earlier binding precedent, the Court held that the issues affected other similar matters and justified reference for fuller consideration. The matter was therefore directed to be placed before the Acting Chief Justice for decision on reference to a larger Bench.

---

---

Issues: Whether the matter should be placed before a larger Bench for authoritative consideration of the questions arising from the reassessment notices.

Analysis: The controversy involved the taxability of arrears of rent received in a later year, the scope of reassessment under sections 147 and 148, the effect of the four-year limitation, and the interplay between the heads of income and the provisions governing income from house property. The Court found that the questions raised were substantial, affected other similar matters, and required a more detailed examination by a larger Bench in the absence of an earlier binding precedent.

Conclusion: The matter was directed to be placed before the acting Chief Justice for consideration of reference to a larger Bench.

Ratio Decidendi: Where a case raises substantial and recurring questions of law affecting the scope of reassessment and chargeability of income, and no earlier precedent governs the issue, reference to a larger Bench is appropriate for authoritative determination.

---