Reassessment notices and Section 147A challenge: writ appeal allowed, quashment set aside, and matter remitted for fresh consideration.

In a writ appeal concerning reassessment notices, the court considered the effect of an intervening amendment inserting Section 147A and a Supreme Court order in an identical fact situation. It declined to examine the rival merits at that stage, set aside the Single Judge's order that had quashed the notices for lack of jurisdictional competence, and remitted the matter for fresh consideration. The assessees were given liberty to amend the writ petitions and challenge Section 147A, with all contentions kept open.

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Issues: Whether the writ appeal deserved to be allowed by setting aside the order quashing the reassessment notices and remitting the matter for fresh consideration, while reserving liberty to the assessees to challenge Section 147A.

Analysis: In view of the order of the Supreme Court in an identical fact situation and the intervening amendment inserting Section 147A, the Court declined to examine the merits of the rival contentions at this stage. The earlier order of the learned Single Judge, which had quashed the notices on the footing that the jurisdictional Assessing Officers lacked competence, was set aside. The matter was remitted to the learned Single Judge for fresh consideration, with liberty to the assessees to amend the writ petitions and challenge Section 147A and with all contentions kept open.

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 Section 147A.

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