The assessee, a non-resident, had received consideration under a single agreement for grant of exclusive telecast rights of league matches for assessment years 2016-17 to 2018-19. The Assessing Officer issued notice under section 148A(b) on the ground that tax had not been deducted at source from receipts allegedly chargeable to tax in India, thereafter passed order under section 148A(d) and issued notice under section 148. In writ proceedings, the High Court, at the stage of issuing notice, clarified that reassessment proceedings could continue, but any final assessment order passed would not be given effect to and would remain subject to further orders of the Court. Subsequently, the High Court held that the Assessing Officer’s view that there was no basis for bifurcation of receipts in the ratio of 95 per cent and 5 per cent was perverse in light of the agreement and accordingly quashed the notice under section 148A(b), order under section 148A(d) and notice under section 148. On Revenue’s appeal, the Supreme Court held that since a final assessment order had already been passed and the assessee stated that it intended to challenge that assessment independently on its own merits, and not on the grounds urged in the writ petition against the section 148A(d) order, there was no good reason for the Court to examine the Department’s appeal. Accordingly, the Revenue’s appeal was dismissed. (AY. 2016-17 to 2018-19)