Jurisdictional defects in reassessment: notice, recorded reasons and existing material must all align for valid reopening.

Reassessment requires the jurisdictional Assessing Officer to issue the notice and base the recorded reasons to believe on material already on record. Where a notice under section 148 is issued by one officer but the assessment is completed by another after transfer of jurisdiction, the reopening is vulnerable if the jurisdictional requirements are not properly met. The recorded reasons must also match the existing record; a mismatch between the stated basis for reopening and the assessment material shows that the foundation for reassessment is defective. On this analysis, such defects go to jurisdiction and render the reassessment void.

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Issues: Whether the reassessment was valid when the notice under section 148 was issued by one Assessing Officer but the assessment was framed by another who had not issued the notice, and whether the reassessment could stand when the reasons recorded did not match the material available on record.

Analysis: The notice for reassessment was issued by one officer, but jurisdiction was later transferred and the assessment was completed by another officer without issuing the notice under section 148. The reassessment power must be exercised by the Assessing Officer having jurisdiction, and the formation of reasons to believe must rest on existing material. The recorded reasons stated cash deposits of a much higher amount, whereas the assessment order itself reflected a different figure, showing that the reasons were not borne out by the record. Since the foundational requirements for reopening were not satisfied, the reassessment proceedings could not survive.

Conclusion: The reassessment was without jurisdiction and void, and the addition made in the reassessment was quashed.

Final Conclusion: The assessee succeeded on the challenge to reopening and the reassessment order was set aside in entirety.

Ratio Decidendi: Reassessment is invalid where the notice or reasons to believe are not issued or recorded by the jurisdictional Assessing Officer or are not supported by the existing record, because such defects go to the root of jurisdiction and render the proceedings void.

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