Reassessment order invalid for ignoring filed objections, with matter remitted for fresh consideration of the assessee's reply.

Reassessment initiation and the order under Section 148A(d) were vitiated because the assessee's filed objections and supporting documents were not considered before further action was taken. The record showed objections had been submitted in response to the Section 148A(b) notice, but the impugned order proceeded as if no reply had been filed. The HC therefore quashed the reassessment-related order and consequential notices, and remitted the matter to the assessing authority for fresh consideration of the objections and for passing a lawful order.

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Issues: Whether the reassessment initiation and the order under Section 148A(d) of the Income-tax Act, 1961, along with the consequential notices and orders, were liable to be quashed for non-consideration of the petitioner's objections and whether the matter required reconsideration by the assessing authority.

Analysis: The petitioner had filed objections and supporting documents in response to the notice under Section 148A(b) of the Income-tax Act, 1961. The order under Section 148A(d) proceeded on the footing that no reply had been filed, although the record showed objections dated 25.03.2023, 26.03.2023, and 13.04.2023. Since the objections were not taken into account before proceeding further, the impugned reassessment-related orders and consequential proceedings could not be sustained.

Conclusion: The impugned order and consequential notices were quashed, and the matter was remitted to the authority for fresh consideration of the objections and for passing an appropriate order in accordance with law.

Final Conclusion: The writ petition succeeded, the reassessment proceedings were set aside, and the authority was directed to reconsider the matter after examining the petitioner's objections.

Ratio Decidendi: A reassessment order passed without considering the assessee's filed objections and supporting material is vitiated and requires fresh consideration in accordance with law.

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