Non-supply of reopening reasons before reassessment completion vitiates the process and quashes the assessment entirely.

A reassessment under section 143(3) read with section 147 is unsustainable where the recorded reasons for reopening are not supplied to the assessee before completion of assessment. Repeated requests at the assessment stage did not secure disclosure, and furnishing the reasons only during Tribunal proceedings did not cure the defect because it denied the assessee an effective opportunity to object to the reopening. Applying the settled principle that non-supply of recorded reasons before completion vitiates reassessment, the reassessment was quashed as invalid on jurisdictional grounds.

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Issues: Whether reassessment framed under section 143(3) read with section 147 of the Income-tax Act was valid when the reasons recorded for reopening were not supplied to the assessee before completion of assessment.

Analysis: The reasons for reopening were recorded, but they were furnished to the assessee only during the appellate proceedings before the Tribunal, despite repeated written requests made during the assessment stage. This deprived the assessee of the opportunity to file objections against the reopening before the assessment was completed. In the light of the settled principle that non-supply of recorded reasons before completion of reassessment vitiates the reassessment, the assessment could not be sustained.

Conclusion: The reassessment was quashed as invalid, and the assessee succeeded on the jurisdictional challenge.

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