Reopening Quashed for Non-Supply of Reasons – Entire Assessment Held Void

M. Abbas & CO. Vs ACIT (ITAT Mumbai) Mumbai ITAT quashed reassessment proceedings holding that failure to supply the actual recorded reasons for reopening vitiates the entire assessment. The Tribunal observed: The AO had only provided a “gist/text of reasons” instead of the actual recorded reasons for reopening This violated the mandatory requirement laid down by the Supreme Court in GKN Driveshafts Without proper supply of reasons, the assessee was deprived of the right to object, breaching principles of natural justice The ITAT held that: Recording and supplying reasons is the fou...