Reassessment notices remitted for fresh consideration after amendment changed the legal basis; liberty preserved to challenge the new provision.

The High Court set aside the Single Judge's quashing of reassessment notices and remitted the matter for fresh consideration because a Supreme Court order in an identical situation meant the legal foundation had changed after the amending legislation. It declined to examine the merits of the rival contentions at that stage, preserved the assessee's liberty to challenge the newly inserted provision, and allowed the Revenue to place further submissions within the timelines indicated. All contentions were kept open for reconsideration on remand.

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Issues: Whether the writ appeal against quashing of reassessment notices and the connected order of the learned Single Judge should be allowed, with the matter remitted for fresh consideration and liberty reserved to challenge the newly inserted provision.

Analysis: In view of the order of the Supreme Court in an identical fact situation, the foundational basis on which the notices had been quashed stood altered by the amending legislation. The parties also sought disposal in terms of the Supreme Court's directions. The Court therefore declined to examine the merits of the rival contentions at this stage, set aside the order under appeal, remitted the matter to the learned Single Judge, and preserved liberty for the assessee to challenge Section 147A and for the Revenue to file further submissions within the timelines indicated.

Conclusion: The writ appeal was allowed, the order of the learned Single Judge was set aside, and the matter was remitted for fresh consideration with liberty to challenge the amendment and with all contentions kept open.

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