Overlapping reassessment proceedings can be quashed only for the already concluded period, not for the remaining assessment year.

Where reassessment proceedings had already been completed for April to July 2009, a later notice and consequential order for the broader 2009-10 assessment year could not stand to the extent they duplicated the concluded period. The court confined interference to the overlapping period and declined to quash the entire proceedings because the remaining part of the assessment year had not been covered by the earlier reassessment. The challenge therefore succeeded only in part, with the reassessment quashed for April to July 2009 and allowed to continue for the balance period.

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Issues: Whether reassessment proceedings for the same turnover period were duplicative and liable to be quashed in full, or only to the extent they covered a period already concluded.

Analysis: The earlier reassessment had already been completed for the period April to July 2009. The later notice and consequential order, though framed for the broader assessment year 2009-10, could not survive insofar as they covered the same already-assessed period. At the same time, the remaining part of the assessment year was not covered by the earlier concluded proceedings, so there was no basis to quash the entire set of proceedings. The proper course was to confine interference only to the overlapping period.

Conclusion: The challenge succeeded only in part. The proceedings were quashed for the period April to July 2009, and they were permitted to continue for the remaining period.

Final Conclusion: Interference was limited to the overlapping reassessment period, leaving the balance of the assessment proceedings intact.

Ratio Decidendi: Where reassessment proceedings already stand concluded for a defined period, subsequent proceedings may be quashed only to the extent of that duplication and not for distinct periods not earlier adjudicated.

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