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Reassessment procedure requires the Assessing Officer to decide...
Prior disposal of reopening objections is mandatory before scrutiny notice; premature scrutiny invalidates reassessment and consequential assessment orders.
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Reassessment procedure requires the Assessing Officer to decide an assessee's objections to reopening through a speaking order before commencing scrutiny assessment. A scrutiny notice initiates scrutiny and cannot be issued before those objections are disposed of. Premature initiation of scrutiny is a jurisdictional defect, rather than a procedural irregularity, rendering the reassessment proceedings and consequential assessment order invalid. The reassessment and consequential assessment order were quashed, making challenges to the assessment's merits academic.
Reassessment procedure requires the Assessing Officer to decide an assessee's objections to reopening through a speaking order before commencing scrutiny assessment. A scrutiny notice initiates scrutiny and cannot be issued before those objections are disposed of. Premature initiation of scrutiny is a jurisdictional defect, rather than a procedural irregularity, rendering the reassessment proceedings and consequential assessment order invalid. The reassessment and consequential assessment order were quashed, making challenges to the assessment's merits academic.
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