In Reopening AO cannot pass Composite Order for Assessment and for rejection of objection

Brief about the case In the case of JVS Export vs. The Deputy Commissioner of Income Tax, the assessee, being a partnership firm, received notice u/s 148 on the ground that the AO has reason to believe that the income of the petitioner firm chargeable to tax had escaped assessment within the meaning of Section 147 of the Income Tax Act,1961. On query by the assesee the AO furnished reason for issue of notice being stating that there is payment of foreign sales agents commission for which no TDS has been deducted. Relying on GKN Driveshaft (India) Ltd Vs. ITO (259 IT19)(SC) the petitioner firm ...