Reassessment challenge remanded for fresh consideration after hearing, with no merits ruling on the impugned notices and order.

Reassessment proceedings under the Income-tax Act were not finally adjudicated in writ jurisdiction; instead, the challenge to the notices under section 148, the order under section 148A(d), and the consequential notice was left for fresh consideration by the Assessing Officer. The Court did not rule on the merits of the impugned reassessment actions and, in light of the Revenue's request for remand, directed the petitioner to file the chart before the Assessing Officer, who was to grant a hearing and pass appropriate orders within four weeks.

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Issues: Whether the challenge to the notices and order issued in reassessment proceedings under the Income-tax Act, 1961 should be finally adjudicated in writ jurisdiction or sent back to the Assessing Officer for reconsideration and fresh orders.

Analysis: The petition was filed against the notice under section 148, the order under section 148A(d), the consequential notice under section 148, and the connected proceedings. The Revenue sought remand so that the Assessing Officer could apply his mind to the facts and pass appropriate orders in accordance with law, and reliance was placed on a similar course adopted by the Supreme Court in another matter. In view of that stand, the Court did not decide the validity of the impugned reassessment actions on merits and instead directed the petitioner to place the chart before the Assessing Officer, who was to grant a hearing and then pass appropriate orders within four weeks.

Conclusion: The reassessment challenge was not quashed on merits, and the matter was directed to be considered afresh by the Assessing Officer after hearing the petitioner.

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