Separate assessment orders remain valid when separately noticed and issued simultaneously, with merits challenges routed through statutory appeals.

Separate assessment orders for different assessment years may be issued simultaneously where separate notices were issued, separate orders were made, and the assessee had an opportunity to file objections. In the absence of a statutory prohibition, simultaneous issuance does not make the orders invalid merely because they were passed together. Principles against composite assessment proceedings do not apply in those circumstances. Challenges to the merits of the assessments must be pursued through the statutory appellate remedy.

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Issues: Whether separate assessment orders for different assessment years, issued simultaneously after separate notices, are legally invalid merely because they were passed together.

Analysis: The absence of a statutory prohibition permits separate orders for different assessment years to be issued simultaneously. The principles against composite assessment proceedings do not apply where separate notices and separate orders are issued and the assessee is given an opportunity to submit objections. The remaining merits-based challenges require invocation of the statutory appellate remedy.

Conclusion: Simultaneous issuance of separate assessment orders for different assessment years is not illegal on that ground, and the merits-based challenges are to be pursued through the statutory appellate remedy.

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