Dayanidhi Maran: S.148 Recording of reasons does not mean that same should be communicated along with notice itself

Dayanidhi Maran Vs ACIT (Madras High Court)

Section 148 speaks about “the issuance of notice where income has escaped assessment”. Section 148(2) stipulates that “the Assessing Officer shall, before issuing any notice under this Section, record his reasons for doing so”. Whether the said provision can be interpreted as if recorded reasons by the Assessing Officer should be communicated along with the notice. The very purport of the Act is to ensure that the Assessing Officers are acting with reasons and judiciously.

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