Income Tax Law does not mandate the AO to suo moto supply the reasons for reopening / reassessment to the assessee

CIT Vs. Safetag International India Pvt Ltd (Delhi High Court)- In the present case, the assessee did not ask for these “reasons to believe”. The assessee rather participated in the reassessment proceedings. When the reassessment orders were passed and the assessee felt aggrieved there against, the assessee filed appeal before the CIT (A). In this appeal, he challenged the validity of reassessment proceedings, which was the course of action available to the assessee.

The CIT (A), thus, could examine the is

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