Reassessment reopening scrutiny turns on production of original approval records before notice under tax law

Reopening of assessment was questioned on the basis of whether the original approval records under Section 151 were produced and whether valid approval preceded notice under Sections 147 and 148. The HC did not decide the merits at this stage; it adjourned the matter with a direction to produce the original documents on the next date and imposed costs for delay.

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Issues: Whether the notice for reopening of assessment could be examined further without production of the original approval records, and whether the authority competent under Section 151 of the Income-tax Act, 1961 had in fact granted approval before issuance of notice under Sections 147 and 148.

Outcome: The matter was adjourned with a direction to produce the original documents on the next date, and costs were imposed for delay.

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