Reopening of assessment and limitation under the new reassessment regime governed by the Rajeev Bansal ruling.

Reopening of assessment under section 147, including notice under section 148A(b) issued after the limitation period, was treated as governed by the Supreme Court's earlier decision in Union of India v. Rajeev Bansal. The Court applied that ruling to Special Leave Petitions concerning the scope of TOLA and the interaction between the new regime under the Finance Act, 2021 and the earlier reopening framework. The Revenue's petitions were disposed of, and the Assessing Officer was directed to decide the objections in accordance with the law laid down in that judgment.

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Outcome: Delay condoned. The special leave petitions filed by the Revenue were disposed of in view of the law laid down in the earlier judgment, and the assessing officers were directed to act in accordance with that law.

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