Reassessment reopening remains valid when reasons were recorded earlier, and section 151 approval is not shown absent on record.

Furnishing reassessment reasons after issuance of notice under section 148 does not invalidate reopening where the Assessing Officer had already recorded the reasons to believe before the notice was issued, because the later supply of reasons only reflects compliance with reassessment procedure. A challenge to reassessment for want of approval under section 151 also fails where the assessee cannot place the approval on record or otherwise establish its absence. On these principles, both additional grounds to reopen the assessment were rejected, and the reassessment challenge did not succeed.

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Issues: (i) Whether the reopening was invalid because the reasons recorded under section 147 were furnished after issuance of the notice under section 148; (ii) Whether the reassessment was invalid for want of approval under section 151.

Issue (i): Whether the reopening was invalid because the reasons recorded under section 147 were furnished after issuance of the notice under section 148.

Analysis: The record showed that the Assessing Officer had already recorded the reasons to believe and the assessee was later furnished those reasons in compliance with the directions governing reassessment procedure. The sequence reflected furnishing of reasons after notice, not recording of reasons after notice.

Conclusion: The first additional ground was rejected and the reopening was held to be valid.

Issue (ii): Whether the reassessment was invalid for want of approval under section 151.

Analysis: The assessee was unable to place the approval on record and sought time or a direction to the department to produce it. The Tribunal held that the ground could not succeed in the absence of the requisite material in the record and found no merit in the contention.

Conclusion: The second additional ground was rejected and the reassessment was not invalidated on this basis.

Final Conclusion: The reassessment challenge failed on both additional grounds and the appeal was dismissed.

Ratio Decidendi: Furnishing reassessment reasons after issuance of notice does not by itself invalidate the reopening where the reasons were recorded earlier, and a challenge to reassessment based on lack of section 151 approval fails when the approval is not shown on the record.

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