Reassessment notice and independent quasi-judicial discretion: assessing authority must decide objections objectively, uninfluenced by superior directions.

A reassessment notice is not invalid merely because it is issued on information received from another authority. However, a superior authority cannot issue directions that fetter the assessing authority's quasi-judicial discretion. The assessing authority must consider the objections and the reassessment issue independently, objectively, and on its own merits, without being influenced by directive communications. Reassessment proceedings may continue, but the decision-making process must comply strictly with law and preserve independent application of mind.

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Issues: Whether the reassessment notice could be interfered with, and whether the assessing authority was required to act independently and objectively notwithstanding directions from a superior authority.

Analysis: The notice proposing reassessment was not barred merely because it had been issued on the basis of information received from another authority. However, a superior authority's positive direction on how the matter should be dealt with could fetter the discretion of the assessing authority in the exercise of its quasi-judicial function. The proper course was to ensure that the assessing authority examined the objections and the reassessment issue on its own merits, without being influenced by the directive communication.

Conclusion: The reassessment proceedings were permitted to continue, but the assessing authority was required to decide the matter strictly in accordance with law, independently and objectively, uninfluenced by the superior authority's directions.

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