Court sets aside assessment orders for lack of reasons, directs separate objections disposal.

The court quashed assessment orders in four petitions challenging the failure to provide reasons for reopening assessments and to dispose of objections separately, contrary to apex court directives. The court emphasized the importance of complying with legal obligations, leading to setting aside the assessment orders and directing separate speaking orders on objections. The judgment highlighted the necessity of following proper procedures and respecting apex court directives, ultimately annulling the assessment orders in all four petitions.

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Issues:
Challenges to assessment orders based on failure to provide reasons for reopening, failure to dispose of objections separately, passing common orders on objections and reassessment, and failure to follow the law laid down by the apex court.

Analysis:
The judgment involves four petitions by sister concern companies challenging assessment orders for the assessment year 2001-02 issued by the Income-tax Officer. The petitioners' principal grievance is based on the apex court's judgment in CKN Driveshafts (India) Ltd. v. ITO, which emphasizes the obligation to provide reasons for issuing a notice under section 148 of the Income-tax Act and to dispose of objections separately.

In the first matter, the petitioner sought reasons for reopening the assessment multiple times, but the reasons were not provided promptly. The assessment order was passed without addressing the objections separately. Similar issues were present in the next three petitions, where common orders were passed on objections and reassessment. The court noted that in previous assessment years, similar issues were resolved by setting aside the assessment orders to dispose of objections properly.

The court highlighted that the officer was aware of the legal obligations but failed to follow them in the current assessment year. The petitioners had filed appeals to the Commissioner of Income-tax (Appeals), but the court found it necessary to intervene due to the non-compliance with the apex court's directives. The orders challenged were against the law laid down by the apex court, justifying the exercise of writ jurisdiction to quash the assessment orders in all four petitions.

As a result of setting aside the assessment orders, the appeals filed by the petitioners were no longer necessary. The court directed the first respondent to pass separate speaking orders on the objections filed by the petitioners, with a provision to withhold the assessment order if objections are rejected for four weeks. The judgment clarified that it did not reflect any opinion on the merits of the impugned orders and made the rule absolute with no order as to costs.

In conclusion, the judgment emphasizes the importance of following legal procedures, providing reasons for reopening assessments, and disposing of objections separately as mandated by the apex court, leading to the quashing of assessment orders in all four petitions.

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