Interim relief in reassessment proceedings declined where delay, prior response, and later objections weighed against stay of assessment.

Interim relief in a challenge to reassessment proceedings under the Income-tax Act was declined because the assessee approached the Court belatedly after the Section 148A(d) order, had already responded to the prior Section 148A(b) notice, and again raised objections after the Section 142(1) notice. The Court permitted the revenue to continue with the assessment process, while the petition remained pending for further orders.

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Issues: Whether interim relief should be granted against reassessment proceedings initiated under the Income-tax Act, 1961.

Analysis: The petition challenged the reopening order and the consequential reassessment steps. Interim protection was declined in view of the delay in approaching the Court after the order under Section 148A(d), the prior notice under Section 148A(b), the response already filed, and the fact that the assessee again raised objections after the notice under Section 142(1). The authorities were permitted to proceed with assessment, while the petition was kept pending for further orders.

Outcome: Interim relief was rejected and the respondents were permitted to continue with the assessment proceedings.

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