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2022 (6) TMI 29 - MADRAS HIGH COURTReopening of assessment u/s 147 - Rejection of objections pursuant to the 148 notice - HELD THAT:- Assessment orders were passed under Section 147 of the Act, prior to which, 148 notice was issued and the objections were raised, which were rejected through the impugned order. Challenging the assessment orders writ petitions were filed and the same were allowed by a separate order passed by this Court today, where, after setting aside those assessment orders, matters were remitted back to the Assessing Authority with a direction to issue fresh show cause notice by giving not less than one week time to the petitioner assessee to respond. Therefore, the said directions issued by this Court shall be scrupulously followed and executed punctually by the respondent Assessing Authority. Therefore, at this juncture, the present challenge made against the 148 notice or the rejection order with regard to the objections raised by the petitioner for the proposed opening of assessment under Section 147 may not stand in the way. If any additional reasons have been given by the Assessing Authority, the same can also be objected to, for which, reply can be given with supporting documents and inputs by the petitioner assessee along with the reply to be given to the show cause notice which is going to be issued by the respondent Assessing Authority pursuant to the orders passed in the other writ petitions referred to above. After considering all these reply or inputs to be supplied by the petitioner, the Assessing Authority can go ahead with the assessment process and complete the same by passing an order of assessment, if need arises. Therefore, the present challenge made against these orders in these writ petitions may not hold good for the purpose of legal scrutiny and decision
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