Special Leave Petitions by revenue disposed; reopening assessments under Section 147/149 and Section 3 of TOLA governed by precedent

SC held the Special Leave Petitions by the revenue are covered by the Court's earlier decision and are disposed of. Reopening of assessment/time-limit issues under Section 147/149 and applicability of Section 3 of TOLA (with COVID period exclusion) are to be governed by that precedent. Assessing Officer must decide outstanding objections in accordance with the law laid down; the anonymized assessee may pursue statutory remedies thereafter, except on issues conclusively settled by the Court's prior judgment.

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"Delay condoned." The Special Leave Petitions are held to be "squarely 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." Consequently, the petitions filed by the Revenue are disposed of and "the assessee 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, an aggrieved assessee may "pursue all the rights and remedies in accordance with law, save and except for the issues which have been concluded in the Judgment." Pending applications, if any, also stand disposed of. The order limits re-litigation to matters not foreclosed by the cited precedent and mandates administrative compliance with the Court's legal conclusions before permitting further remedy.

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