Earlier judgment governs SLPs challenging reassessment notices under Sections 147/148/148A; TOLA and 2021 Finance Act provisions to apply

SC held that the SLP challenging reassessment notices is covered by the Court's earlier decision and dismissed the Revenue's petitions. The reopening/time-limit and validity of notices under sections 147/148/148A, and the applicability of TOLA and the Finance Act, 2021 reassessment provisions, are to be determined in accordance with the reasons given in the earlier SC judgment. The HC decision favoring the taxpayer is subsumed by the SC ruling; the assessee is governed by the principles laid down in that prior judgment.

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Delay condoned. The Special Leave Petition is held to be covered by the Court's judgment dated 3-10-2024 in Union of India & Ors. v. Rajeev Bansal (Civil Appeal No.8629/2024 etc.) 2024 (11) Scale 473, and accordingly the petition filed by the Revenue is disposed of. "The assessee will be governed by reasons discussed in the said Judgment." Assessing officers are directed to dispose of objections "in terms of the law laid down by this Court." Thereafter, an aggrieved assessee may pursue "all the rights and remedies in accordance with law," except as to issues already concluded in the referenced judgment. Pending applications, if any, are disposed of.

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