Court voids assessment order for failure to address objections before proceeding. Taxpayers' objections must be resolved promptly.

The Court set aside the assessment order and all consequential steps, including the notice under Section 271 of the Act of 1971, due to the Assessing Officer's failure to address the petitioners' objections before proceeding with the assessment under Section 148 of the Income Tax Act, 1961. The Court emphasized the need for the Assessing Officer to resolve objections raised by taxpayers before finalizing assessments and directed the Officer to evaluate the objections within four weeks from the date of the order. The writ petition was disposed of without costs.

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Issues:
Challenge to proceeding under Section 148 read with Section 147 of the Income Tax Act, 1961 and notice under Section 271 of the Act of 1971.

Analysis:
The petitioners challenged the reopening of assessment for three assessment years under Section 148 of the Income Tax Act, 1961. The Department provided reasons for the reopening, and the petitioners responded to it. The petitioners contended that the authorities should have disposed of their objections before proceeding with the assessment. However, the Assessing Officer proceeded with the assessment without addressing the objections, which the Court found to be improper. The Court held that the Assessing Officer should have first resolved the objections raised by the petitioners before proceeding with the assessment under Section 148.

The Court noted that the Assessing Officer's failure to address the objections before passing the assessment order was not in accordance with the law. Therefore, the impugned assessment order was set aside, along with all consequential steps taken, including the notice under Section 271 of the Act of 1971. The Court emphasized that the Assessing Officer must evaluate the objections raised by the petitioners within four weeks from the date of the order and proceed thereafter in accordance with the law.

In conclusion, the Court disposed of the writ petition and did not award any costs. The judgment highlighted the importance of addressing objections raised by taxpayers before finalizing assessments under Section 148 of the Income Tax Act, 1961.

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