Reassessment reasons must be disclosed once a return is filed after section 148 notice, ensuring a fair hearing.

After a return is filed in response to a notice under section 148, the reassessment proceedings become quasi-judicial, and the Assessing Officer must disclose the recorded reasons for reopening. The officer cannot refuse such disclosure once proceedings have commenced in this manner, because communication of the reasons is necessary to enable effective participation in the reassessment process. The assessee is therefore entitled to have the assessment continue only after receiving the recorded reasons and being given an opportunity of being heard.

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Issues: Whether, after the assessee had filed a return in response to a notice under section 148, the Assessing Officer was obliged to disclose the recorded reasons for reopening the assessment.

Analysis: The notice for reopening was issued under section 148 of the Income-tax Act, 1961. Once the assessee had submitted a return in response to that notice, the proceedings had acquired a quasi-judicial character. In such a , the Assessing Officer could not refuse disclosure of the reasons already recorded for reopening and was bound to communicate them to enable further participation in the assessment proceedings.

Conclusion: The recorded reasons for reopening had to be disclosed to the assessee, and the assessee was entitled to have the assessment proceeded with only after such disclosure and after being given an opportunity of being heard.

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