Income-tax reassessment notices for AY 2021-22 and earlier: s.148 barred if old 6-year limit expired; 10-year window prospective

The dominant issue was the validity of reassessment notices issued under the post-2021 regime in light of limitation under s. 149 read with TOLA, particularly whether the extended 10-year period could be invoked for AY 2021-22 and earlier despite expiry of the 6-year period under the pre-amendment regime. Applying the binding ratio in a prior SC decision, the Court held that issuance of notice under s. 148 is barred where the pre-amendment 6-year limitation had already expired on the date of notice, and the amended 10-year window under s. 149 operates prospectively. The revenue's SLPs were disposed of accordingly, with objections to be decided by the AO per SC law.

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Delay in filing the Special Leave Petitions was condoned. The Court held that these petitions are fully "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 Revenue's petitions were disposed of without independent adjudication on the merits, with the Court directing that the assessee "will be governed by reasons discussed in the said Judgment." The Court further directed that the assessing officers "will dispose of the objections in terms of the law laid down by this Court." Assessees aggrieved by such orders may pursue all rights and remedies in accordance with law, "save and except for the issues which have been concluded in the Judgment." All pending applications were also disposed of.

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