2025 (2) TMI 1270 - SCH - Income Tax

Reopening under s.147 and notice under s.148A(b) to follow reasons in earlier 3-10-2024 judgment; AO to decide objections

Special Leave Petitions by the Revenue were dismissed; reopening of assessment under s.147 and issuance of notice under s.148A(b) (as amended by the ... Validity of reopening of assessment u/s 147 - notice beyond period of limitation - Notice under section 148A(b) of New Law as amended by Finance Act, 2021 - scope of TOLA - New regime v/s old regime - HELD THAT:- These Special Leave Petitions are covered by the Judgment of this Court rendered on 3-10-2024 in “Union of India & Ors. vs. Rajeev Bansal” (2024 (10) TMI 264 - SUPREME COURT (LB) Petitions filed by the Revenue are disposed of. The assessee will be governed by reasons discussed in the said Judgment. AO will dispose of the objections in terms of the law laid down by this Court. 'Delay condoned.' These Special Leave Petitions are held to be covered by the Judgment dated 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, any assessee aggrieved 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, are disposed of.