Recorded reasons in reassessment must be disclosed after a Section 148 return, with proceedings held in abeyance pending reply.

Where a return is filed in response to a notice under Section 148 of the Income-tax Act, the Assessing Officer should communicate the recorded reasons for initiating reassessment, subject to protecting the source or informant if necessary. The assessee must then be given an opportunity to file a reply within one week of such disclosure. Pending that disclosure and reply, the reassessment proceedings should not be completed.

---

---

Issues: Whether, after filing a return in response to a notice under Section 148 of the Income-tax Act, 1961 and seeking a copy of the recorded reasons, the assessee was entitled to disclosure of those reasons, and whether the reassessment proceedings should remain stayed until such disclosure and a reply was filed.

Analysis: The writ petition was disposed of by following the existing view that, where a return is filed pursuant to a notice under Section 148, the Assessing Officer should communicate the reasons recorded for initiating reassessment, while preserving the necessity of protecting the source or informant if the authority considers such protection necessary. The order also provided the assessee an opportunity to file a reply within one week after communication of the reasons, and directed that the proceedings pursuant to the impugned notices would not be completed in the meantime.

Conclusion: The petitioner was granted disclosure of the reasons recorded under Section 148, with consequential protection against completion of the reassessment proceedings until the reasons were communicated and a reply was filed.

---