Recorded reasons for reopening are mandatory; failure to furnish reasons and dispose objections voids the reassessment.

Failure to furnish recorded reasons for reopening and to dispose of the assessee's objections renders a reassessment procedurally invalid: the document explains that furnishing recorded reasons on request is mandatory and objections must be considered before reassessment proceeds, and that non-compliance produces a jurisdictional defect requiring quashing of the reassessment. The ruling applies binding precedents holding that reassessment completed without these steps is bad in law, and where those procedural defects exist the substantive merits become academic and the reassessment is set aside.

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Issues: Whether the reassessment framed under Section 147/Section 148 of the Income-tax Act, 1961 is invalid and liable to be quashed because the Assessing Officer failed to furnish recorded reasons and to pass a separate order disposing of the assessee's objections to the notice for reopening.

Analysis: The issue concerns compliance with the requirement that recorded reasons for reopening an assessment must be furnished to the assessee when sought and that objections to reopening must be considered before proceeding with reassessment. The tribunal applied binding precedents establishing that furnishing recorded reasons on request is mandatory and that failure to dispose of objections and to furnish reasons results in a jurisdictional defect in the reassessment proceedings. The tribunal relied on prior decisions applying the principle that reassessment completed without complying with these steps is bad in law.

Conclusion: The reassessment order passed under Section 147/Section 148 of the Income-tax Act, 1961 is set aside and quashed for failure to furnish recorded reasons and to dispose of the assessee's objections; the assessee's legal ground is allowed. Other merits-related grounds are rendered academic.

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