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ITAT held that the reassessment proceedings were jurisdictionally infirm and directed annulment of the resultant assessment. The Tribunal found the AO did not adjudicate the assessee's specific objections and that the purported draft order did not reflect disposal of objections, rendering the proceedings procedurally defective. Consequentially, the assessment order framed under section 147 read with section 144B was set aside and the notice issued under section 148 was quashed. The Tribunal allowed the additional ground raised by the assessee and remitted no matter for fresh exercise of jurisdiction in the absence of valid compliance with mandated objection-disposal procedure.
ITAT held that the reassessment proceedings were jurisdictionally infirm and directed annulment of the resultant assessment. The Tribunal found the AO did not adjudicate the assessee's specific objections and that the purported draft order did not reflect disposal of objections, rendering the proceedings procedurally defective. Consequentially, the assessment order framed under section 147 read with section 144B was set aside and the notice issued under section 148 was quashed. The Tribunal allowed the additional ground raised by the assessee and remitted no matter for fresh exercise of jurisdiction in the absence of valid compliance with mandated objection-disposal procedure.
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TaxTMI 
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