Subsequent tax-period order cannot stand once a final determination for that period already exists

A subsequent order for the same tax period cannot be sustained where a final order for that period had already been passed and was under appeal. The text states that the challenged order dated 23 April 2024 related to the same tax period as the earlier final order dated 01 February 2021, so the later order lacked basis and could not stand. On that footing, the impugned order was quashed and the writ petition was allowed.

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Issues: Whether an order passed for the same tax period could be sustained when a final order had already been passed for that period and was under appeal.

Analysis: The challenged order dated 23 April 2024 was found to relate to the same tax period as the final order dated 01 February 2021. Since the earlier proceedings had already culminated in a final determination for that period, the subsequent order was treated as having been passed without basis and could not stand.

Conclusion: The impugned order dated 23 April 2024 was quashed and the writ petition was allowed.

Ratio Decidendi: A subsequent order for an already concluded tax period cannot be sustained where a final order for that very period has earlier been passed.

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