Failure of A.O. to dispose objections raised render re-assessment invalid

The assessee filed its return of income on 02.12.2013, which was processed u/s 143(1) at the returned income and accordingly refund order of Rs. 20,16,957/- was issued. Subsequently A.O. based on reporting made by statutory auditor in the audit report in the form of 3CD u/s 44AB that the ‘management service fee to the extent of Rs. 1,36,89,075 payable to Tupperware International Holdings EV Ltd. was paid without deducting tax at source’ issued notice u/s 148 on 21.10.2005 recording that since the said deduction was inadmissible under Section 40(a)(i) of the Act, he had reasons to believe t...