Mandatory disposal of reopening objections before reassessment can vitiate the entire reassessment process.

The requirement to furnish reopening reasons and dispose of the assessee's objections by a speaking order before completing reassessment is mandatory. Where objections are raised against reassessment and are not decided before the reassessment order is passed, the reassessment proceedings are vitiated. On the facts described, the reassessment notice and the consequential reassessment order were quashed in favour of the assessee.

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Issues: Whether the reassessment notice and the consequential reassessment order were liable to be quashed for failure to dispose of the assessee's objections before completing the assessment.

Analysis: The assessee sought reasons for reopening, received them, and filed objections to the reassessment. The objections were not disposed of by a speaking order before the reassessment order was passed. The requirement to furnish reasons and decide objections before proceeding with assessment is mandatory, and non-compliance vitiates the reassessment proceedings.

Conclusion: The reassessment notice and the consequential reassessment order were quashed, and the issue was decided in favour of the assessee.

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