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    <title>2025 (8) TMI 1492 - ITAT MUMBAI</title>
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    <description>Reassessment is invalid where the Assessing Officer completes proceedings without first disposing of the assessee&#039;s objections to reopening by a speaking order. The procedure in GKN Driveshafts, together with natural justice, requires those objections to be adjudicated before further reassessment steps continue. Here, the reopening was also challenged as lacking new tangible material and as a change of opinion, but the decisive defect was the failure to decide the objections before finalising reassessment. On that basis, the assumption of jurisdiction for reassessment was held to be without authority, and the reassessment notice and order were set aside in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=777304</link>
      <description>Reassessment is invalid where the Assessing Officer completes proceedings without first disposing of the assessee&#039;s objections to reopening by a speaking order. The procedure in GKN Driveshafts, together with natural justice, requires those objections to be adjudicated before further reassessment steps continue. Here, the reopening was also challenged as lacking new tangible material and as a change of opinion, but the decisive defect was the failure to decide the objections before finalising reassessment. On that basis, the assumption of jurisdiction for reassessment was held to be without authority, and the reassessment notice and order were set aside in favour of the assessee.</description>
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