Section 147 Assessment invalid if reasons recorded for reopening not furnished

Shri Vijaykumar L. Jain Vs ITO (ITAT Pune) The issue under consideration is whether Non-furnishing of reasons recorded for reopening of assessment made the entire assessment u/s 147 invalid in law? ITAT states that, in the present case it is clear that despite the request by the assessee, the Assessing Officer has completed the assessment without furnishing the reasons recorded for reopening of assessment. Furnishing the reasons recorded for reopening of the assessment is mandatory condition as held by the Hon’ble Supreme Court in the case of GKN Driveshafts (India) Ltd. Vs. ITO (supra) ...