Limitation challenge to reassessment notices under Section 148 succeeded after the court followed its earlier binding ruling.

Orders passed under Section 148A(d) and notices issued under Section 148 were challenged as time-barred. The matter was treated as covered by a recent Bombay High Court decision, and the Revenue accepted that position. On that basis, the Court disposed of the petitions by following the earlier binding ruling and recorded that the impugned orders and notices, together with any consequential actions, stood quashed and set aside in favour of the petitioners.

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Issues: Whether the orders passed under Section 148A(d) of the Income-tax Act, 1961 and the notices issued under Section 148 of the Income-tax Act, 1961 were liable to be quashed and set aside on the ground of limitation.

Analysis: The petitions were stated to be covered by a recent decision of the same Court, and the Revenue agreed. The Court therefore treated the issue as concluded by the earlier binding decision and disposed of the matters on that basis.

Conclusion: The impugned orders under Section 148A(d) and the notices under Section 148 were quashed and set aside, along with consequential notices or orders, if any, in favour of the petitioners.

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