Reassessment notice procedure under Section 148 requires return, recorded reasons, objections, and a speaking order before further action.

On receipt of a reassessment notice under Section 148, the assessee should first file a return and may then seek the recorded reasons for reopening. The Assessing Officer must supply those reasons within a reasonable time, after which the assessee may file objections to the reopening. Those objections must be decided by a speaking order before reassessment proceedings continue. A writ petition challenging the notices at that stage was treated as premature, and no interference was warranted with the order dismissing it.

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Issues: Whether a writ petition challenging notices issued for reassessment under the Income-tax Act was premature, and what procedure must be followed after issuance of notice under Section 148.

Analysis: On receipt of notice under Section 148, the proper course is for the assessee to file a return and, if so advised, seek the reasons recorded for reopening. The Assessing Officer must furnish those reasons within a reasonable time. After receiving the reasons, the assessee is entitled to file objections to the reopening, and the Assessing Officer is bound to dispose of the objections by passing a speaking order before proceeding further with the reassessment. In the facts before it, the Court found no justification to interfere with the order dismissing the writ petition.

Conclusion: The challenge to the reassessment notices did not warrant interference, and the writ petition was correctly treated as premature; the reassessment could proceed only after supply of reasons and disposal of objections by a speaking order.

Ratio Decidendi: When reassessment notice is issued under Section 148 of the Income-tax Act, the assessee must first file a return, may seek recorded reasons, and is entitled to a speaking order on objections before reassessment proceedings continue.

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