Amendment to writ petition rejected where dismissal left no live controversy despite later reassessment jurisdiction changes.

An amendment application to a writ petition challenging reassessment notices was rejected where the writ petition had already been dismissed and no live controversy survived. The later insertion of concurrent jurisdiction under Section 147A of the Income-tax Act was noted as consistent with the Court's earlier view on notice-issuing competence, but it did not revive the closed proceeding. The Supreme Court's remand order was understood to permit amendments in pending matters to challenge the amended provision, not to reopen a dismissed writ. On that basis, the amendment request was treated as misconceived and dismissed at the threshold.

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Issues: Whether the petitioner's application to amend the writ petition was liable to be allowed in view of the Supreme Court's remand order and the amendment introducing concurrent jurisdiction under Section 147A of the Income-tax Act, 1961.

Analysis: The Court noted that the subsequent amendment to Section 147A of the Income-tax Act, 1961 provided for concurrent jurisdiction of the Faceless Assessing Officer and the Jurisdictional Assessing Officer, which was consistent with the Court's earlier view on the competence to issue notices under Section 148 of the Income-tax Act, 1961. It further noted that the Supreme Court's order had set aside only the judgments in favour of the assessees and had granted liberty to amend writ petitions to challenge the amended provision, whereas the present writ petition had already been dismissed and no live issue survived for amendment.

Conclusion: The application for amendment was rejected as misconceived.

Final Conclusion: The petitioner obtained no relief, and the application stood dismissed at the threshold.

Ratio Decidendi: Where the underlying writ petition has already been dismissed and the subsequent legislative amendment does not revive a live controversy in the pending proceeding, an amendment application seeking to challenge that amendment is misconceived and liable to be rejected.

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