Reassessment notices under Section 148 must be individually tested for limitation, threshold conditions, and faceless procedure compliance.

Writ petitions challenging reassessment notices under Section 148 were addressed by requiring individual re-examination under the Supreme Court's binding rulings on limitation, the substituted reassessment regime, and the monetary threshold for escaped income. The Court recognised that the applicability of time-bar rules and the surviving limitation period depended on the facts of each assessee's case, so each notice had to be tested separately. The competent officer was directed to apply the faceless procedure, communicate the decision to the assessee, and leave the statutory remedy open if any assessee remained aggrieved.

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Issues: Whether the bunch of writ petitions challenging notices under Section 148 of the Income-tax Act, 1961 required adjudication on merits or could be disposed of by directing the revenue to re-examine each case in the light of the Supreme Court's ruling on limitation, the substituted reassessment regime, and the monetary threshold for escaped income.

Analysis: The governing legal position had already been settled by the Supreme Court on the interaction between the old and substituted reassessment provisions, the continued operation of the relaxation legislation, the exclusion of periods for limitation purposes, and the requirement that notices beyond the surviving time limit are time-barred. The Court noted that the factual position differed from assessee to assessee and that individual determination was necessary to see whether a particular notice survived limitation or fell below the monetary threshold. It therefore directed the competent officer to examine each case in light of the Supreme Court's directions, apply the faceless procedure, and communicate the decision to the assessee, leaving the statutory remedy open if any assessee remained aggrieved.

Conclusion: The writ petitions were not decided on the merits of the individual reassessment notices; instead, they were disposed of with a direction to the revenue to decide each case afresh in accordance with the Supreme Court's binding ruling and the applicable statutory procedure.

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