Reasons for initiating assessment u/s 147 should be recorded prior to issuance of notice u/s 148

The only question here is whether reasons could at all be recorded after issuance of the notice under Section 148 of the Act. And, secondly, that as the reasons were recorded after the issuance of Section 148 notice, whether the proceedings were not vitiated. Decision of the High Court of Karnanataka – Commissioner of Income Tax, (Exemptions) v. Baldwin Boys High School: 364 ITR 637(Karnataka) – this very question of whether a notice under Section 148 of the said Act could be issued without recording reasons came up for consideration. The Karnataka High Court observed as under:- “6. ...