Reassessment Without Furnishing Reasons Invalid: ITAT Mumbai

Raghunandan Bhomia Vs DCIT (ITAT Mumbai)

Assessee was searched u/s 132 & based on information available from the seized material, AO made additions on account of unexplained money & jewellery u/s 69A. 148 notice was issued after recording reasons. Despite a specific request by assessee, AO did not supply the reasons for reopening assessment.

In appeal, assessee had relied on the Supreme Court’s decision in GKN Driveshafts ( India) Ltd. vs. ITO [2002] wherein it was held that without furnishing the reasons recorded by AO, the completion of assessment is not

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