2025 (9) TMI 917 - SCH - Income Tax

Special Leave Petitions follow prior TOLA ruling on Income Tax Act and scope of notices under Section 148

SC held the Special Leave Petitions are governed by its prior decision on the applicability of TOLA to the Income Tax Act and the scope of notices under ... Validity of reassessment notices/ proceedings - scope of notices issued u/s 148 of the new regime between July and September 2022 - Application of TOLA to the Income Tax Act after 1 April 2021 - TOLA enacted in the backdrop of the COVID-19 pandemic by extending time limits for completion or compliance of actions under specified Acts - Interpretation of expression “any” in Section 3(1) of TOLA - non obstante clause HELD THAT:- These Special Leave Petitions are squarely covered by the Judgment of this Court rendered in “Union of India & Ors. vs. Rajeev Bansal” [2024 (10) TMI 264 - SUPREME COURT (LB)] Petitions filed by the Revenue are disposed of. The assessees will be governed by reasons discussed in the said Judgment. AO will dispose of the objections in terms of the law laid down by this Court. Thereafter, the assessees who are aggrieved will be at liberty to pursue all the rights and remedies in accordance with law, save and except for the issues which have been concluded in the Judgment. 'Delay condoned.' The Special Leave Petitions are held to be 'squarely covered by the Judgment of this Court rendered on 3-10-2024 in 'Union of India & Ors. vs. Rajeev Bansal' (Civil Appeal No. 8629/2024 etc.) 2024 (11) Scale 473.' Consequently, the petitions filed by the Revenue are disposed of, and the assessees '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, assessees who remain aggrieved are at liberty to pursue 'all the rights and remedies in accordance with law,' except for issues already concluded in the cited Judgment. Pending applications, if any, are also disposed of.