Reassessment notice invalid without recorded reasons before issue; jurisdiction under section 148 could not be sustained.

A reassessment notice under section 148 is invalid where the Assessing Officer has not recorded reasons before issuing it, because recording reasons is a mandatory jurisdictional requirement under section 148(2). The document states that, since no recorded reasons were available on the assessment record or furnished to the assessee, the assumption of reassessment jurisdiction could not be sustained. On that basis, the notice was treated as without jurisdiction and bad in law, and the reassessment addition was deleted.

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Issues: Whether the reassessment notice issued under section 148 was valid when the Assessing Officer had not recorded reasons before issuing the notice, and whether the reassessment made on that basis could be sustained.

Analysis: The reopening was challenged on the ground that all primary facts had been disclosed in the original assessment and that no recorded reasons for issuing notice under section 148 were available on the assessment record or furnished to the assessee. The statutory requirement under section 148(2) that reasons must be recorded before issuing notice was treated as mandatory. In the absence of any recorded reasons, the assumption of jurisdiction for reassessment could not be supported.

Conclusion: The notice under section 148 was held to be without jurisdiction and bad in law, and the reassessment addition was deleted. The appeal was dismissed.

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