Court directs respondent to address petitioner's objections promptly, emphasizing due process.

The court found merit in the petitioner's objection that there was no income escapement finding for the proposed verification exercise. It directed the respondent to dispose of the petitioner's objections by passing a speaking order within four weeks. The court refrained from interfering with the notices but left all contentions open for further review based on the assessing officer's response to the objections. The writ petitions were disposed of with a direction for the respondent to address the petitioner's objections properly, emphasizing the importance of following due process as outlined in the GKN Driveshafts case.

---

---

Issues:
1. Validity of notice under Section 148 of the Income Tax Act for reopening assessments.

Analysis:
The petitioner, a Doctor, filed income tax returns for different assessment years which were accepted. However, a survey under Section 133A was conducted at a hospital premises, leading to a notice under Section 148 for reopening assessments. The petitioner objected to the reasons recorded for reopening, stating they were for verification, not for income escapement. The respondent justified the proceedings, leading to the filing of writ petitions challenging the notices.

The petitioner contended that for one assessment year, the notice for scrutiny proceedings could only be issued by a certain date, as per Section 143(2) of the Act. Citing a Madras High Court decision, the petitioner argued against the reopening notice's validity before the expiry of the scrutiny notice period.

The respondent, however, relied on a Supreme Court decision and argued against rushing to court at the notice stage. The court considered both parties' arguments and examined the reasons for reopening the assessments. The court referred to the GKN Driveshafts case, emphasizing the need for the assessing officer to furnish reasons and dispose of objections by passing a speaking order.

The court found merit in the petitioner's objection that there was no income escapement finding for the proposed verification exercise. It directed the respondent to dispose of the petitioner's objections by passing a speaking order within four weeks. The court refrained from interfering with the notices but left all contentions open for further review based on the assessing officer's response to the objections.

In conclusion, the writ petitions were disposed of with a direction for the respondent to address the petitioner's objections properly. The court emphasized the importance of following due process as outlined in the GKN Driveshafts case and allowed the petitioner the opportunity to revisit the court based on the assessing officer's response to the objections.

---