Reassessment jurisdiction fails when recorded reasons are not supplied or produced, and the resulting assessment is annulled.

Reassessment under sections 147 and 148 was invalid because the recorded reasons for reopening were not supplied to the assessee, were not produced before the appellate forums, and were not otherwise on record. The validity of notice under section 148 had to rest on reasons existing before the notice was issued, and later developments could not cure the defect. The record also showed pre-notice inquiries despite no pending proceedings and without authority under section 133, so the assumption of jurisdiction was unsupported and unauthorized. The assessment made pursuant to the reopening was annulled.

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Issues: Whether reassessment under section 147 read with section 148 of the Income-tax Act, 1961 was valid in the absence of recorded reasons being supplied or produced, and whether the assessment made pursuant to such reopening was liable to be annulled.

Analysis: The reasons recorded for reopening were not supplied to the assessee, were not produced before the first appellate authority or the Tribunal, and were not otherwise available on the record. The validity of reopening must rest on the recorded reasons existing before issue of notice under section 148, and developments after assumption of jurisdiction cannot cure the defect. The record also showed that inquiries were made before issue of notice under section 148 despite no pending proceedings and without authority under section 133. On these facts, the assumption of jurisdiction was held to be unsupported and unauthorized.

Conclusion: Reassessment under sections 147 and 148 was invalid, and the assessment order was annulled.

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