https://www.taxtmi.com/caselaws?id=259997 Reassessment proceedings were challenged on the ground that the statutory "reasons to believe" were not recorded before issuance of notice under s. 148 and that objections to reopening were not disposed of by a prior speaking order. Applying s. 148(2) and HC precedents, the HC held that reasons must be recorded before the s. 148 notice; recording them after the notice renders the notice and all consequential proceedings without authority of law, so the reopening was invalid. Relying on SC law, the HC further held that the AO must decide objections by a separate speaking order before completing reassessment; failure vitiated the reassessment, and relief was granted to the assessee. en-us Thu, 21 May 2015 00:00:00 +0530 Mon, 13 Apr 2026 11:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259997 Reassessment proceedings were challenged on the ground that the statutory "reasons to believe" were not recorded before issuance of notice under s. 148 and that objections to reopening were not disposed of by a prior speaking order. Applying s. 148(2) and HC precedents, the HC held that reasons must be recorded before the s. 148 notice; recording them after the notice renders the notice and all consequential proceedings without authority of law, so the reopening was invalid. Relying on SC law, the HC further held that the AO must decide objections by a separate speaking order before completing reassessment; failure vitiated the reassessment, and relief was granted to the assessee. Case-Laws Income Tax Thu, 21 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259997