Failure to consider reassessment objections under Section 148A(d) led to setting aside the order and notice.

An order under Section 148A(d) of the Income-tax Act cannot be sustained where it proceeds on the incorrect factual premise that no objections were filed and fails to consider the assessee's response on merits. Here, the record showed filed objections supported by acknowledgement receipts, and the respondents did not effectively dispute their authenticity. As the authority did not deal with the objections before issuing the reassessment notice under Section 148, both the order and consequential notice were set aside, with liberty to reconsider the objections afresh in accordance with law.

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Issues: Whether the order passed under Section 148A(d) of the Income-tax Act, 1961 and the consequential notice under Section 148 of the Income-tax Act, 1961 were liable to be set aside for failure to consider the petitioner's objections.

Analysis: The record showed that objections had been filed to the reassessment notices and supported by acknowledgement receipts. The respondents did not effectively dispute the authenticity of those system-generated acknowledgements. The impugned order proceeded on the premise that no objections had been filed and therefore did not consider the petitioner's response on merits. An order passed on such an incorrect factual premise and without dealing with the objections could not be sustained.

Conclusion: The order under Section 148A(d) was set aside, and the consequential notice under Section 148 was also set aside, with liberty to the respondents to consider the objections afresh and proceed in accordance with law.

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