HC Reverses Law on Supply of Reasons for Reopening – Need not be supplied within limitation period

Validity of reassessment proceedings is not affected if reasons are recorded by the Assessing Officer for reopening the assessment but not furnished to the taxpayer within a limitation period There is no requirement in Section 147 or Section 148 or Section 149 that the reasons recorded should also accompany the notice issued under Section 148. The requirement in Section 149(1) is only that the notice under Section 148 shall be issued. There is no requirement that it should also be served on the assessee before the period of limitation. There is also no requirement in Section 148(2) that the re...