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Issues Involved:
The judgment involves issues related to the validity of an assessment order under section 143(3) of the Income-tax Act, 1961 for the assessment year 1962-63, specifically addressing the timeliness of the order and compliance with principles of natural justice. Validity of Assessment Order: The High Court considered whether the order recorded in the order sheet entry on April 11, 1967, constituted a valid assessment order under section 143(3) and if it was within the time limit prescribed by law. The Tribunal held that the order sheet entry mentioning the assessed income and tax to be paid was a valid assessment order, even though it lacked detailed reasoning. The Court agreed that the entry was valid but emphasized the importance of a speaking order that provides reasons for decisions affecting the assessee's rights. Compliance with Principles of Natural Justice: The Court further examined whether the failure to provide a detailed and reasoned order violated the principles of natural justice, rendering the assessment null and void. It was acknowledged that while the violation of natural justice may result in illegality or irregularity, it does not necessarily invalidate the entire assessment process. Citing legal precedents, the Court concluded that the error in the assessment order was curable, and the Assessing Officer should be directed to pass a fresh order after affording the assessee an opportunity to be heard. The judgment highlighted the importance of reasoned orders to enable the right to appeal and prevent arbitrariness. Conclusion: The Court upheld the Tribunal's decision that the original assessment order was invalid but not a nullity, directing the Assessing Officer to redo the assessment in compliance with the law and principles of natural justice. Both issues were answered in the affirmative in favor of the Revenue, emphasizing the need for fair procedures and substantial justice.
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