Section 148 notice challenge remand sustained, with reassessment objections to be decided first and appellate issues heard by speaking order.

The Supreme Court declined to interfere under Article 136 with the High Court's remand directing the Assessing Officer to first decide objections to the validity of the Section 148 notice before continuing reassessment, finding the appellant's procedural interests adequately protected. It also held that, because an assessment order had been passed and an appeal was pending before the Commissioner of Income Tax (Appeals), the appellant may raise all issues before that authority, which must decide them by a speaking order. The appeals were dismissed and the remand order was left undisturbed.

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Outcome: Appeals dismissed; no interference with the High Court order remitting the matter to the Assessing Officer, leaving the appellant to pursue objections before the Commissioner of Income Tax (Appeals).

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