Premature assessment before expiry of objection period violates natural justice and is void.

An assessment finalised before the expiry of the period granted for filing objections was without jurisdiction and offended natural justice, because the assessee was denied the full opportunity to respond to the pre-assessment notice. The authority acted on a mistaken calculation of the objection deadline and completed the best judgment assessment while time still remained for objections. The premature order could not be sustained, and the assessment was held illegal and void, with the order quashed in favour of the assessee.

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Issues: Whether the assessment made under section 18(4) before expiry of the period for filing objections was without jurisdiction and violative of natural justice.

Analysis: The assessee received the pre-assessment notice with seven days' time to object, but the assessment was finalised before that period had expired. The record showed that the authority proceeded on a mistaken calculation of the last date for objections and completed the best judgment assessment on a date when the assessee still had time to respond. An assessment made before the expiry of the objection period could not be sustained, as the assessee was denied a fair opportunity and the authority acted without jurisdiction in finalising the order prematurely.

Conclusion: The assessment order was illegal and void and was quashed in favour of the assessee.

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