Reassessment reopening requires disclosure of recorded reasons before further assessment action can proceed.

Reassessment under section 148 cannot proceed without first confronting the assessee with the recorded reasons for reopening or furnishing a certified copy of those reasons. The court directed that, before any further reassessment action, the Income-tax Officer must disclose the substance of the reasons or provide a certified copy, ensuring the assessee has an opportunity to know the basis of the reopening before assessment continues.

---

---

Issues: Whether reassessment proceedings initiated under section 148 could proceed without confronting the assessee with the reasons recorded for reopening, and whether the assessee was entitled to inspect or receive a copy of those reasons before further assessment action.

Outcome: The writ petition was disposed of with a direction that, before proceeding further with the reassessment, the Income-tax Officer must confront the assessee with the substance of the recorded reasons or furnish a certified copy thereof.

---