Binding interpretation of reassessment limits under tax law required the court to follow earlier precedent and grant relief.

A writ challenge to reassessment was resolved by applying the binding interpretation of Section 149 of the Income-tax Act, 1961. The court treated the issue as covered by an earlier Division Bench ruling construing the first and third provisos to Section 149 as effective from 01.04.2021, and noting the later renumbering of the third proviso from 01.04.2023. Because that precedent governed the legal question and had itself followed an earlier decision on the same point, the impugned reassessment action could not be sustained and the writ petition was allowed.

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Issues: Whether the writ petition challenging the impugned reassessment action was liable to be allowed in view of the governing interpretation of Section 149 of the Income-tax Act, 1961.

Analysis: The issue was treated as covered by a Division Bench decision which had examined the first and third provisos to Section 149 of the Income-tax Act, 1961, as in force from 01.04.2021, and noted the subsequent renumbering of the third proviso with effect from 01.04.2023. The Court held that, despite the respondents' submissions, it was bound by the earlier Division Bench ruling, which itself had followed a prior decision on the same legal question.

Conclusion: The writ petition was allowed.

Final Conclusion: The impugned action could not be sustained once the issue was held to be governed by the earlier binding interpretation of Section 149, and the petitioner obtained the substantive relief sought.

Ratio Decidendi: When a legal issue is already covered by a binding prior decision of a coordinate or superior Bench, the Court must follow that interpretation and grant relief accordingly.

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