Recorded reasons and objection opportunity are mandatory before reassessment proceedings; premature statutory notices render the reassessment invalid.

Reassessment procedure requires the Assessing Officer to provide recorded reasons within a reasonable time, allow the taxpayer to file objections, and dispose of those objections by a speaking order before proceeding with reassessment. Issuing a notice under Section 142(1) before supplying requested reasons, and issuing further notices under Sections 142(1) and 143(2) simultaneously with supplying those reasons, without time to object, breaches this mandatory sequence. The notes state that the reassessment notice and consequential assessment order were void ab initio and quashed.

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Issues: Whether reassessment proceedings were valid where the Assessing Officer commenced assessment proceedings before furnishing recorded reasons and issued statutory notices simultaneously with furnishing those reasons, without allowing an opportunity to object.

Analysis: The prescribed reassessment procedure requires recorded reasons to be supplied within a reasonable time, followed by an opportunity to file objections and their disposal through a speaking order before the Assessing Officer proceeds with reassessment. The Assessing Officer issued a notice under Section 142(1) before supplying the requested reasons and, on the date of supplying the reasons, simultaneously issued further notices under Sections 142(1) and 143(2), without affording time for objections. This constituted non-compliance with the mandatory procedure.

Conclusion: The reassessment notice and the consequential assessment order were void ab initio and were quashed, in favour of the assessee.

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