Reopening of assessment under the new reassessment regime governed by Rajeev Bansal principles and pending objections

Validity of reopening under Section 148A(d) under the Finance Act 2021 regime, including the scope of TOLA and the transition between the old and new reassessment framework, was treated as covered by the Supreme Court's ruling in Rajeev Bansal. The Revenue's petitions were disposed of, and the Assessing Officer was directed to decide the objections in accordance with that law. An assessee aggrieved by the reassessment action may pursue available legal remedies, except on issues already concluded by the binding judgment.

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Outcome: The special leave petition filed by the Revenue was disposed of in terms of the earlier judgment, and the assessee was directed to be governed by that decision.

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