Binding precedent in reassessment disputes led to quashing of notices, orders and consequential demand and penalty proceedings.

Reassessment notices and orders were treated as covered by an earlier binding Bombay HC decision in Hexaware Technologies Limited, and the consequential demand and penalty notices could not survive. Because the controversy for the different assessment years was accepted by both sides as governed by that precedent, the impugned reassessment proceedings were quashed and set aside, along with any reassessment orders, demand notices, and penalty notices arising from them. The petitions were disposed of in favour of the petitioners, with liberty to raise any contention not covered by the earlier decision if required.

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Issues: Whether the impugned reassessment notices and orders, along with consequential demand and penalty notices, were liable to be quashed as covered by an earlier binding judgment.

Analysis: The petitions related to different assessment years, and both sides accepted that the controversy was governed by the Court's earlier decision in Hexaware Technologies Limited. On that basis, the impugned notices and orders were treated as covered by the precedent, and the consequential proceedings could not survive.

Conclusion: The impugned notices and orders were quashed and set aside, and any reassessment orders, demand notices, and penalty notices arising therefrom were also quashed.

Final Conclusion: The petitions were disposed of in favour of the petitioners, with liberty to raise any contention not covered by the earlier decision if the need arose.

Ratio Decidendi: Where the controversy in reassessment writ petitions is already covered by a binding prior decision, the impugned notices, orders, and all consequential proceedings are liable to be set aside.

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