Reassessment procedure requires prior disposal of objections; failure to do so renders the reassessment procedurally void.

Addresses whether reassessment proceedings under Section 148 can validly be completed before disposal of objections filed by the assessee; it identifies disposal of objections as a jurisdictional prerequisite to completing reassessment and finds that disposing objections only after an assessment order attempts post facto validation and produces procedural nullity. The piece concludes that commencement and completion of reassessment without prior disposal of objections results in invalid reassessment (void ab initio) and that such procedural defect supports allowance of the assessee's challenge to the reassessment.

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Issues: Whether initiation and completion of reassessment proceedings under Section 148 of the Income-tax Act, 1961 without disposing of objections filed by the assessee against reopening is valid.

Analysis: The reassessment was initiated under Section 148 of the Income-tax Act, 1961 and reasons were supplied. The assessee filed objections through the e-portal on 22.03.2022. The record shows disposal of those objections by the Assessing Officer only on 07.03.2024, which is after the assessment order dated 29.03.2022. The appellate record reproduced the letter dated 07.03.2024 as disposal of objections. The procedural requirement that objections raised against reopening must be disposed of before completion of reassessment is a jurisdictional prerequisite. The facts indicate that the Assessing Officer disposed of the objections only during appellate proceedings, after the assessment order had been passed, thereby attempting to validate proceedings post facto.

Conclusion: The initiation and completion of reassessment proceedings under Section 148 of the Income-tax Act, 1961 without prior disposal of the assessee's objections is a jurisdictional defect and the reassessment is void ab initio. The assessee's ground is allowed and the appeal is allowed in favour of the assessee.

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