Earlier precedent governs disposal of SLPs; notices under Sections 147/148/148A, TOLA and Finance Act 2021 reassessment follow its ratio

SLPs by the revenue were disposed of as covered by an earlier SC precedent; notices issued under sections 147/148/148A and the applicability of TOLA and the reassessment provisions of the Finance Act, 2021 are to be governed by the ratio of that precedent. Assessees will be bound by the reasons in the said SC judgment and the AO must dispose of objections in accordance with the law and the guidance provided by the SC.

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Delay condoned. The Special Leave Petitions are held to be "covered by the Judgment of this Court rendered on 3-10-2024 in 'Union of India & Ors. vs. Rajeev Bansal' (Civil Appeal No.8629/2024 etc.) 2024 (11) Scale 473." Accordingly, the petitions filed by the Revenue are disposed of and "the assessees will be governed by reasons discussed in the said Judgment." Assessing officers are directed to "dispose of the objections in terms of the law laid down by this Court." Thereafter, aggrieved assessees are at liberty to pursue all rights and remedies in accordance with law, subject to the caveat that issues concluded by the cited Judgment are final. The operative effect is adherence to the precedent in the Rajeev Bansal decision, disposal of revenue petitions on that basis, and remand to assessing officers for implementation consistent with that legal framework.

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