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Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination before orders.
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Section 148A requires the assessee to receive information suggesting income has escaped assessment, not the source of that information. Particulars in the annexure to a reassessment show-cause notice may satisfy this requirement where they identify the basis and reasons sufficiently for a response; non-disclosure of an audit objection does not invalidate the notice. However, where an assessee asserts that a taxable marked-to-market hedge-reserve amount was included in an earlier year, the assessing authority must verify that claim and its consequences. Failure to do so requires reconsideration after hearing the assessee, including additional supporting material.
Section 148A requires the assessee to receive information suggesting income has escaped assessment, not the source of that information. Particulars in the annexure to a reassessment show-cause notice may satisfy this requirement where they identify the basis and reasons sufficiently for a response; non-disclosure of an audit objection does not invalidate the notice. However, where an assessee asserts that a taxable marked-to-market hedge-reserve amount was included in an earlier year, the assessing authority must verify that claim and its consequences. Failure to do so requires reconsideration after hearing the assessee, including additional supporting material.
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