IN THE HIGH COURT OF JUDICATURE AT BOMBAY TRUSHA T M U O S H H I A TE R ORDINARY ORIGINAL APPELLATE JURISDICTION DTMRi O gUi H tSa IHl T y EA sTigUnSeHdA bRy D18a:t4e3: :24032 +6.00513.008 WRIT PETITION (L) NO. 913 OF 2025 MPS Merchandisers Pvt. Ltd .. Petitioner Versus Union of India & Ors. .. Respondents Adv. Mahaveer Jain a/w Adv. Bhavesh Bhatia i/b Adv. Neha Anchlia, for the Petitioner.

Adv. Akhileshwar Sharma, for the Respondents.

CORAM: B. P. COLABAWALLA &

FIRDOSH P. POONIWALLA, JJ.

DATE: JANUARY 6, 2026 P. C.

1. In the above Writ Petition (alongwith other Writ Petitions filed by the very same Petitioner) Rule was issued on 11^th February, 2025. However, interim relief was refused for the reasons more particularly set out in the said order. The Assessee being aggrieved, approached the Hon’ble Supreme Court. The Hon’ble Supreme Court, by its order dated 7^th March, 2025 [passed in Petition for Special Leave to Appeal No. 5748 of 2025] inter alia directed that the assessment proceedings may continue and the Assessing Officer was given liberty to decide the issue of limitation as a preliminary issue. However, no final order of assessment on merits would be passed, was the direction of the Hon’ble Supreme Court.

2. Pursuant to the directions passed by the Hon’ble Supreme Court, the issue of limitation has been decided by the Assessing Officer for Assessment Year 2010-11 to Assessment Year 2013-14, and he has dropped the proceedings. The subject matter of the present Petition is Assessment Year 2014-15. The Assessing Officer, pursuant to the directions given by the Hon’ble Supreme Court, is in the process of determining the issue of limitation even for the current Assessment Year.

3. Considering these facts and circumstances, we request the Assessing Officer to decide the issue of limitation for Assessment Year 2014- 15 as well, as expeditiously as possible and in any event within a period of 60 days from today.

4. We now place the above Writ Petition on board on 9^th March, 2026. In the event, the Assessing Officer decides the issue of limitation prior to the next date, liberty is given to the parties to mention the above matter.

5. Stand over to 9^th March, 2026.

Assistant of this Court. All concerned will act on production by fax or email of a digitally signed copy of this order.

[FIRDOSH P. POONIWALLA, J.] [B. P. COLABAWALLA, J.]