2025 (5) TMI 1596 - SCH - Income Tax

Validity of reassessment notices/ proceedings - time limit for issuance of notice for reopening of the assessment - Validity of order u/s 148A - scope of new enactment of Section 148A - Period of limitation to issue notice issued u/s 148A(b) - HELD THAT - These Special Leave Petitions are squarely covered by the Judgment of this Court rendered in Rajeev Bansal 2024 (10) TMI 264 - SUPREME COURT (LB) Petitions filed by the Revenue are disposed of. The assessee will be governed by reasons discussed in the said Judgment. AO will dispose of the objections in terms of the law laid down by this Court. Thereafter the assesses who are aggrieved will be at liberty to pursue all the rights and remedies in accordance with law save and except for the issues which have been concluded in the Judgment.

Summary

The Supreme Court of India, per Justices J.B. Pardiwala and R. Mahadevan, condoned delay and disposed of the Special Leave Petitions filed by the Revenue, holding them "squarely covered by the Judgment of this Court rendered on 3-10-2024 in Union of India & Ors. vs. Rajeev Bansal." The Court directed that assessing officers shall dispose of objections in accordance with the law as laid down in that precedent. Aggrieved assessees retain the right to pursue remedies consistent with the Judgment, except on issues conclusively decided therein. Pending applications were also disposed of.