Reopening of assessment and TOLA application to post-31 March 2021 section 148 notices governed by Rajeev Bansal.

Reopening of assessment under the old regime, and the reach of TOLA for AY 2015-16, were treated as covered by the Supreme Court's decision in Union of India v. Rajeev Bansal. Notices issued under section 148 after 31 March 2021 were to be dealt with in accordance with that judgment, including the question whether such notices relate back to the original date. The Assessing Officer was directed to dispose of objections in terms of the law laid down by the Court, and the assessee was left free to pursue available rights and remedies on issues not already concluded.

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Outcome: The Special Leave Petition in the first matter was dismissed for delay and on merits, and the connected petition in the second matter was disposed of in view of the binding judgment referred to in the order.

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