Reassessment fails for non-supply of reopening reasons and use of the wrong statutory regime after amended procedure applied.

Non-furnishing of the reasons recorded for reopening before completion of reassessment vitiates the proceedings by denying the assessee an effective opportunity to object. Notices issued on 01.04.2021 attracted the amended reassessment framework, and completion under the unamended regime was treated as a jurisdictional illegality. On both grounds, the reassessments were held invalid and the assessee's appeals succeeded.

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Issues: (i) Whether reassessment orders were vitiated for non-supply of the reasons recorded for reopening; (ii) whether notices under section 148 issued on 01.04.2021 attracted the amended reassessment procedure and, if so, whether proceeding under the unamended regime invalidated the assessments.

Issue (i): Whether reassessment orders were vitiated for non-supply of the reasons recorded for reopening.

Analysis: The assessee repeatedly sought the reasons recorded for reopening, but they were not furnished either by the Assessing Officer or at the first appellate stage. The obligation to supply reasons before completing reassessment is mandatory, and failure to do so deprives the assessee of an effective opportunity to object to the reopening.

Conclusion: This issue was decided in favour of the assessee, and the reassessment orders were held invalid on this ground.

Issue (ii): Whether notices under section 148 issued on 01.04.2021 attracted the amended reassessment procedure and, if so, whether proceeding under the unamended regime invalidated the assessments.

Analysis: The notice dates reflected issuance on 01.04.2021. On that basis, the amended reassessment framework was applicable, but the Assessing Officer continued under the unamended provisions. Proceeding under the wrong statutory regime constituted a jurisdictional illegality affecting the validity of the reassessments.

Conclusion: This issue was decided in favour of the assessee, and the reassessment orders were held to be null and void.

Final Conclusion: Both reassessment orders were struck down as illegal, and the assessee's appeals succeeded.

Ratio Decidendi: Reassessment is invalid where the reasons recorded for reopening are not furnished to the assessee and where the assessment is completed under a reassessment procedure that does not apply on the date the notice is issued.

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