Incomplete recorded reasons for reopening reassessment are jurisdictionally fatal and can invalidate the assessment.

Partial or incomplete supply of recorded reasons for reopening a reassessment is treated as a jurisdictional defect because the assessee must receive the full basis for believing income escaped assessment before completion of the proceeding. If material elements are omitted, the disclosure is equivalent to non-furnishing of reasons and the assessee is deprived of an effective opportunity to object. On that footing, the reassessment cannot be sustained and the assessment order, together with the consequential appellate order, is liable to be quashed.

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Issues: Whether partial or incomplete furnishing of the recorded reasons for reopening under reassessment proceedings vitiates the assessment order and the consequential appellate order.

Analysis: The reasons communicated to the assessee were not the same as the reasons recorded in the assessment order. Material elements necessary to disclose why income was believed to have escaped assessment were missing from the reasons furnished to the assessee. The requirement to supply the recorded reasons in full is a jurisdictional safeguard, intended to enable the assessee to object before the reassessment is completed. Incomplete disclosure of the reasons is treated on the same footing as non-furnishing of reasons, and the reassessment cannot be sustained on such a defect.

Conclusion: Partial furnishing of the reasons for reopening was fatal to the reassessment. The assessment order was quashed and the appeal was allowed in favour of the assessee.

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