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The ITAT held that the reopening under section 148A was invalid due to non-disposal of objections raised by the assessee on both merits and legal grounds, violating established precedent. The reopening initiated by the Assessing Officer was therefore not tenable in law. The Tribunal also noted that objections could be raised during reassessment proceedings, reinforcing the invalidity of the reopening. Although the reopening was initiated by the Junior Assessing Officer instead of the First Appellate Officer, this procedural issue was deemed academic as the reopening was quashed on multiple substantive grounds. Consequently, the reassessment proceedings initiated pursuant to the reopening were set aside, affirming that the reopening lacked legal validity and could not be sustained.
The ITAT held that the reopening under section 148A was invalid due to non-disposal of objections raised by the assessee on both merits and legal grounds, violating established precedent. The reopening initiated by the Assessing Officer was therefore not tenable in law. The Tribunal also noted that objections could be raised during reassessment proceedings, reinforcing the invalidity of the reopening. Although the reopening was initiated by the Junior Assessing Officer instead of the First Appellate Officer, this procedural issue was deemed academic as the reopening was quashed on multiple substantive grounds. Consequently, the reassessment proceedings initiated pursuant to the reopening were set aside, affirming that the reopening lacked legal validity and could not be sustained.
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