3-10-2024 judgment governs SLPs on Section 148 reassessment notices and TOLA; assessing officers must decide objections per law

The SC held these SLPs are governed by the Court's earlier judgment of 3-10-2024 concerning the validity and scope of reassessment notices under Section 148 and the applicability of TOLA. Assessing officers must dispose of objections in accordance with the law and the reasons in that judgment. Assessees may pursue available rights and remedies thereafter, except as to issues conclusively decided by the earlier judgment.

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There is a "gross delay" in filing the Special Leave Petitions which has not been satisfactorily explained. The petitions are "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," and the assessees "will be governed by reasons discussed in the said Judgment." Assessing officers are directed to dispose of objections "in terms of the law laid down by this Court." Thereafter, aggrieved assessees may "pursue all the rights and remedies in accordance with law, save and except for the issues which have been concluded in the Judgment." The petitions filed by the Revenue are disposed of in terms of the said Judgment, with the delay not condoned. Pending applications, if any, also stand disposed of.

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