Recorded reasons for reopening must be disclosed on request, or reassessment fails for denying effective objection rights.

Recorded reasons for reopening must be supplied to an assessee on request within a reasonable time, allowing objections to be filed and decided by a speaking order before reassessment is completed. Non-communication of the reasons, without justification, denies an effective opportunity to challenge the reopening. The notes state that the reassessment and appellate orders were set aside because the recorded reasons were not furnished despite a specific request.

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Issues: Whether a reassessment order can be sustained where the reasons recorded for reopening were not supplied to the assessee despite a specific request.

Analysis: Upon issuance of notice for reassessment, the assessee is entitled to seek the recorded reasons, which must be furnished within a reasonable time so that objections may be filed and decided by a speaking order before completion of assessment. The recorded reasons were admittedly not communicated despite the assessee's request, and no explanation justified that omission. This deprived the assessee of an effective opportunity to challenge the reopening.

Conclusion: The reassessment order and the appellate order were set aside in favour of the assessee because of non-communication of the recorded reasons for reopening.

Ratio Decidendi: On a request by the assessee, recorded reasons for reopening must be furnished before reassessment is completed, enabling objections to be filed and adjudicated through a speaking order.

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