Reassessment reasons must be supplied on request; non-disclosure vitiates reopening and the reassessment cannot stand.

Where reassessment is initiated under Section 148, the recorded reasons for reopening must be furnished to the assessee on request; without them, the assessee cannot effectively contest the reopening. The Madras High Court treated non-supply of the reasons as fatal because the request had been made through the assessee's registered e-mail ID and the Department was bound to disclose the basis of reopening. The reassessment order was therefore quashed, while the authorities were left free to begin fresh proceedings in accordance with law.

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Issues: Whether reassessment proceedings initiated under notice under Section 148 of the Income-tax Act, 1961 were liable to be quashed for failure to furnish the reasons for reopening despite a request made by the assessee.

Analysis: The assessee had sought the reasons for reopening after receipt of notice under Section 148. The request was made through the registered e-mail ID of the assessee, and the record showed that the e-mail address used for the request matched the registered e-mail ID referred to in the assessment order. In reassessment proceedings, the Department is bound to furnish the recorded reasons when sought, and non-supply of such reasons prevents the assessee from effectively responding to the reopening.

Conclusion: The failure to furnish the reasons for reopening was fatal, and the reassessment order was quashed. The respondents were left free to initiate fresh proceedings in accordance with law.

Final Conclusion: The assessee succeeded on the reassessment challenge, and the impugned assessment did not survive.

Ratio Decidendi: Where an assessee requests the reasons for reopening after a notice under Section 148, failure to supply those reasons vitiates the reassessment proceedings.

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