https://www.taxtmi.com/caselaws?id=458399 An objection under Section 148A(b) was treated as having been considered, even though the assessing officer reached a different conclusion on the materials; the challenge was therefore directed mainly at the merits of that factual appreciation, which was not suited to writ interference. The order under Section 148A(d) was also not treated as a final determination, because the reassessment process under Section 147 was still ongoing and the assessee could raise all contentions in the subsequent proceedings. The complaint that the notice was issued by the jurisdictional assessing officer rather than through faceless mode was held to be hyper-technical, as the substance of the notice was unaffected and later proceedings would follow the faceless assessment procedure. en-us Sat, 15 Jul 2023 00:00:00 +0530 Thu, 24 Oct 2024 19:42:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458399 An objection under Section 148A(b) was treated as having been considered, even though the assessing officer reached a different conclusion on the materials; the challenge was therefore directed mainly at the merits of that factual appreciation, which was not suited to writ interference. The order under Section 148A(d) was also not treated as a final determination, because the reassessment process under Section 147 was still ongoing and the assessee could raise all contentions in the subsequent proceedings. The complaint that the notice was issued by the jurisdictional assessing officer rather than through faceless mode was held to be hyper-technical, as the substance of the notice was unaffected and later proceedings would follow the faceless assessment procedure. Case-Laws Income Tax Sat, 15 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458399