SLP on reassessment validity under IT Act Sections 147-151 and TOLA disposed following Rajeev Bansal precedent

SC disposed of the Revenue's SLP concerning validity of reopening of assessment under the new reassessment regime and extended limitation under the IT Act read with TOLA. The Court applied the principles laid down in earlier SC decisions on identical issues, including the larger Bench ruling in Union of India v. Rajeev Bansal, holding that the law declared therein would govern the present dispute. No independent reasoning was added, and the matter was resolved in terms of those precedents. All pending applications in the case were also treated as disposed of.

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Delay in filing the Special Leave Petition was condoned. The Supreme Court did not undertake an independent examination of the merits but disposed of the SLP by expressly following its prior orders dated 02.04.2025 in Civil Appeal No. 5177/2025, *Deepak Steel and Power Limited vs. Central Board of Direct Taxes and Ors.*, and dated 04.04.2025 in SLP (C) Diary No. 57209/2024, *Assistant Commissioner of Income Tax Circle 19(1) and Ors. vs. Nehal Ashit Shah*. The Court also acted "by bearing in mind paragraph 19 (e) and (f)" of its judgment in *Union of India vs. Rajeev Bansal*, Civil Appeal No. 8629/2024, 2024 SCC OnLine 754, thereby indicating that the legal issues raised were already governed by the reasoning and directions in those decisions. All pending applications were disposed of consequentially.

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