Separate assessment orders for different assessment years may be...

Separate assessment orders for different assessment years may be issued simultaneously where each year is supported by a separate notice and separate opportunity to respond. The absence of a statutory prohibition means simultaneous issuance does not, by itself, invalidate the orders. The restriction on composite notices and common assessment orders is directed at preventing prejudice from combining proceedings across years, not at prohibiting coordinated issuance of distinct orders. Accordingly, simultaneous separate orders do not warrant interference, while substantive challenges remain subject to the available statutory appellate remedies.

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