Premature challenge to reassessment material cannot stop the Assessing Officer from completing the statutory reassessment process.

A writ court will not require an Assessing Officer to decide objections to survey material in advance where reassessment under Section 148 of the Income-tax Act has already been initiated. The request for an advance ruling on the evidentiary value of the seized material was treated as premature, because doing so would pre-empt the reassessment process and interfere with the statutory discretion vested in the Assessing Officer. The prayer for an immediate direction to consider the objections first was rejected, no mandamus was issued, and the assessee was left to participate in the reassessment proceedings and file a comprehensive reply within the time granted.

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Issues: Whether a writ court should direct the Assessing Officer to decide in advance the petitioner's objections to the materials collected during survey before completion of reassessment proceedings initiated under Section 148 of the Income-tax Act, 1961.

Analysis: The request for an advance ruling on the evidentiary value of the seized material was held to be premature at the stage of notice under Section 148. Once reassessment proceedings have been set in motion, the procedure under the Income-tax Act governs commencement and completion of the assessment. A direction compelling the Assessing Officer to first rule on the petitioner's objections would effectively pre-empt the reassessment process and fetter the statutory discretion vested in the Assessing Officer.

Conclusion: The prayer for a direction to consider Ext. P13 in advance was rejected, and no writ of mandamus was issued in favour of the petitioner.

Final Conclusion: The writ petition was dismissed, with the petitioner left to participate in the reassessment proceedings and file a further comprehensive reply within the time granted.

Ratio Decidendi: A court will not interdict reassessment proceedings by requiring the Assessing Officer to decide evidentiary objections in advance where such a request is premature and would interfere with the statutory reassessment mechanism.

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