Disclosure of relied-upon reopening material and time-bound reassessment directions issued, with merits left open.

The Bombay HC directed the Revenue to furnish the documents, statements and reports relied upon for forming the belief of escapement of income, and fixed a timeline for the assessee to provide the particulars sought under Section 142(1) to complete reassessment. The Court made clear that it was not deciding the merits of the reopening, and that all rights and contentions of the parties remained open. The petition was disposed of with directions limited to disclosure of relied-upon material and completion of the reassessment process within the stipulated time.

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Issues: Whether the assessee was entitled to be supplied with the documents, statements and reports relied upon by the Revenue for forming the belief of escapement of income, and whether directions were required for completion of the reassessment process.

Analysis: The petition arose after an earlier remand for de novo consideration of the objections to reopening. The assessee again sought disclosure of the material relied upon for the formation of belief regarding escapement of income. The order records that the Revenue should make available the documents relied upon, including statements, and also fixes a timeline for the assessee to furnish the particulars sought in the notice issued under Section 142(1) of the Income-tax Act, 1961. The Court clarified that no observations were made on the merits and that all rights and contentions remained open.

Outcome: Directions issued for disclosure of relied-upon material and for completion of the reassessment process within the stipulated time, with the petition disposed of without adjudicating the merits.

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