Year-wise assessment material must match the relevant assessment year; reliance on another year's figures led to remand.

Assessment under the Income-tax Act cannot be sustained where the show-cause notice and reassessment proceedings rely on figures and materials from a different assessment year. The HC held that year-specific facts must form the basis of assessment, and the authority must clearly confine itself to the correct assessment year. Because the notice did not explain the variation and the order did not show proper year-wise application of material, the assessment was set aside. The matter was remitted to the Assessing Officer for fresh adjudication after giving the assessee an opportunity to be heard and to produce evidence.

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Issues: Whether an assessment order under Sections 147, 144 and 144B of the Income-tax Act, 1961 could be sustained when the show-cause notice and assessment proceedings referred to figures and materials relating to a different assessment year, and whether the matter required remand for fresh adjudication.

Analysis: The notice issued in the reassessment proceedings for the relevant assessment year referred to assessment proceedings for another assessment year, and the assessment order did not clearly show that the authority had confined itself to the correct year-wise facts and figures. The Court held that materials, facts and figures of one assessment year cannot be used for the assessment of another assessment year. In view of this infirmity, and since the show-cause notice did not clarify the basis of the variation, the assessment order was set aside and the matter was remitted for fresh consideration after granting opportunity of hearing and production of evidence.

Conclusion: The assessment order was invalidated and the matter was sent back to the Assessing Officer for fresh adjudication after due opportunity to the assessee.

Final Conclusion: The assessee obtained relief by way of setting aside of the impugned assessment and remand, while the tax dispute was left open for fresh decision on merits.

Ratio Decidendi: Assessment must be founded on the material relevant to the same assessment year, and reliance on figures pertaining to a different assessment year vitiates the assessment and warrants remand for fresh consideration.

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