Relaxation regime bars reassessment notice issued after cutoff date; notice quashed because Revenue had already conceded the point.

Where the Revenue had conceded in an earlier three-judge decision that, for assessment year 2015-16, notices issued on or after 1 April 2021 had to be dropped under the statutory relaxation regime, a notice dated 25 June 2021 could not survive. The Court held that no further adjudication on the merits was required once the notice fell beyond the relevant cutoff date. The impugned notice was quashed and set aside, the writ petitions were allowed, and the connected appeals were disposed of by granting the relief sought.

---

---

Issues: Whether the impugned notice issued for the assessment year 2015-16, dated 25.6.2021, could survive in view of the binding concession accepted in the earlier decision and the statutory relaxation regime.

Analysis: The relief turned on the Revenue's concession in the earlier three-judge decision that, for assessment year 2015-16, all notices issued on or after 1 April 2021 were liable to be dropped as they could not be completed within the period prescribed under the relaxation legislation. The impugned notice having been issued on 25.6.2021, no further adjudication on merits was required.

Conclusion: The impugned notice was liable to be quashed and set aside, and the writ petitions were allowed.

Final Conclusion: The assessee obtained complete relief against the challenged notice, and the connected appeals were disposed of by granting the relief sought.

Ratio Decidendi: Where the Revenue has conceded that notices issued after the relevant cutoff date for a particular assessment year must be dropped under the relaxation regime, a notice issued beyond that cutoff cannot be sustained and is liable to be quashed.

---