Reassessment notice procedure requires supply of recorded reasons, objections from the assessee, and a speaking order before further action.

On receipt of a notice under section 148, the assessee is entitled to be supplied with the recorded reasons within a reasonable time and to file objections before further assessment action is taken. Those objections must then be considered by the assessing officer through a speaking order passed in accordance with law. The stated principle ensures that the assessee is informed of the basis for reopening and has a meaningful opportunity to challenge it before the officer proceeds further.

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Issues: Whether, on receipt of a notice under section 148, the assessee was entitled to be furnished the recorded reasons and given an opportunity to file objections before the assessing officer proceeded further.

Analysis: The assessee complained that reasons for issuing the notice had not been supplied, preventing objections. The Revenue stated that the reasons would be furnished and had already been dispatched. The governing principle applied was that the assessee must be supplied the reasons within a reasonable time and must be allowed to object, after which the assessing officer must decide those objections by a speaking order in accordance with law.

Conclusion: The assessee was entitled to receive the reasons and to have objections considered by a speaking order; the petition was thus disposed of with directions in favour of the petitioner.

Ratio Decidendi: On issuance of a notice under section 148, recorded reasons must be supplied to the assessee within a reasonable time, objections must be invited and considered, and the assessing officer must pass a speaking order before proceeding further.

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