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