Disposal of objections is mandatory before completing reassessment; failure to do so renders the reassessment void and rights preservable.

Where a reopening notice is issued and reasons are furnished, the assessing officer must dispose of the assessee's objections by a speaking order before proceeding to complete reassessment; if objections are rejected the assessee must be afforded adequate time to pursue remedies. Proceeding to pass the assessment immediately without disposing objections or allowing time to seek remedy breaches natural justice and renders the reassessment void. The memorandum applies established requirements on objection disposal and timelines and allows the appeal in favour of the assessee.

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Issues: Whether the reassessment order passed under Section 143(3) read with Section 147 of the Income-tax Act, 1961 is void where the assessing officer proceeded to complete assessment proceedings without disposing of the objections filed by the assessee against reopening.

Analysis: The legal framework requires that when notice under Section 148 is issued and reasons are furnished, the assessee may file objections and the assessing officer is required to dispose of those objections by a speaking order before proceeding with assessment. Where objections are rejected, adequate time must be afforded to the assessee to avail remedies; failure to allow such time and proceeding immediately to pass the assessment infringes principles of natural justice. The Tribunal followed its earlier decision in DCIT v. P3 Properties and applied the established requirements concerning disposal of objections and timelines for passing assessment orders under the Income-tax Act, 1961.

Conclusion: The reassessment order is null and void because the assessing officer proceeded with assessment without disposing of the assessee's objections and without allowing time to seek remedy; the ground challenging jurisdiction is allowed and the appeal is allowed in favour of the assessee.

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