Reason to Believe requirement: reassessment invalid when recording officer differs from assessing officer without fresh or delegated reasons.

Reopening under reassessment law requires that the officer who records the reasons to believe must be competent to assume jurisdiction and complete reassessment; if proceedings are transferred and a different officer frames the assessment without independently recording fresh reasons or valid delegation, the reassessment suffers a jurisdictional and procedural defect. Applying that principle here, reasons were recorded by one officer but the final assessment was framed by another officer without a fresh recorded reason, rendering the reassessment invalid and favourable to the assessee.

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Issues: Whether a reassessment framed under section 143(3) read with section 147 of the Income-tax Act, 1961 is valid where the reasons to believe for reopening were recorded by one Assessing Officer but the assessment order was ultimately framed by a different Assessing Officer.

Analysis: The material shows reasons to believe for reopening were recorded by an Assessing Officer different from the officer who issued the final assessment order. The legal framework governing reassessment requires that the officer who forms the reason to believe must be competent to assume jurisdiction and complete the reassessment proceedings. Where reasons recorded by one officer are relied upon, transfer of the proceeding to another officer without independent re-formation of reasons or lawful delegation raises a jurisdictional defect. Applying this principle to the present facts, the reassessment was initiated on reasons recorded by one officer but the assessment was framed by another officer without a fresh recorded reason by that officer, resulting in a procedural and jurisdictional infirmity. The remaining grounds became infructuous once the jurisdictional defect was upheld.

Conclusion: The reassessment is invalid on the ground that the assessment was framed by a different Assessing Officer than the one who recorded the reasons to believe; this conclusion is in favour of the assessee.

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