Non-quoting of reasons for reopening in reassessment notice would not vitiate entire proceedings

Seshasayee Paper & Boards Ltd. Vs UOI (Madras High Court)

Conclusion: Mere non quoting of the reasons for reopening by AO in the impugned notice would not vitiate the entire proceedings. Department had to furnish the reasons to assessee and on receipt of the reasons, if assessee were of the opinion that there were no additional material or new materials were available then they could submit their objections in respect of the change of opinion or reason to believe.

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