Omission of concluding sentence doesn’t amount to non-furnishing of reasons for reassessment

Brief Facts of the case- This is a petition u/s. 254(2) of the Income-tax Act, 1961 (“the Act”) i.e. rectification petition, preferred by the assessee-appellant, directed against the order u/s. 254(1) passed by the Tribunal. The Miscellaneous Application assails the impugned order on several grounds, raising legal and factual issues. These have been discussed point-wise as under. Issue wise analysis Ground 1– Assessee not been provided the copy of the reasons recorded for re-opening of assessment u/s. 147, but only the gist thereof. Held On facts, the Tribunal had clearly stated t...