Reassessment notices under Sections 148A(d) and 148 were quashed where the dispute was covered by binding precedent.

Where reassessment orders under Section 148A(d) and consequential notices under Section 148 were already covered by a recent binding judgment, and the Revenue accepted that position, the reassessment action could not be sustained. The High Court quashed and set aside the impugned orders and notices, and all consequential proceedings fell with the principal action. Other contentions were left open for future proceedings.

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Issues: Whether the impugned orders under Section 148A(d) of the Income-tax Act, 1961 and the consequential notices under Section 148 of the Income-tax Act, 1961 were liable to be quashed on the ground that the controversy stood covered by a recent judgment of the Court.

Analysis: The petitions were stated to be covered by the recent decision of the Court in a similar matter, and the Revenue accepted that position. In view of that concession and the applicability of the earlier ruling, the impugned reassessment orders and notices could not be sustained. The consequential notices and orders also fell with the principal action.

Conclusion: The impugned orders and notices were quashed and set aside in favour of the assessees.

Final Conclusion: The petitions succeeded and the reassessment proceedings initiated through the impugned orders and notices were annulled, while leaving other contentions open for consideration in appropriate future proceedings.

Ratio Decidendi: Where the issue raised is covered by an earlier binding judgment accepted by both sides, the corresponding reassessment order and notice are liable to be set aside along with all consequential actions.

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