https://www.taxtmi.com/caselaws?id=264451 The HC held that failure to furnish reasons for reopening under Section 148 renders the reassessment order invalid. Recording and providing reasons is a jurisdictional requirement that must be strictly followed to prevent arbitrary reopening. The procedure allows the assessee to challenge the validity of the reasons before reassessment proceeds. The AO must consider objections and either withdraw or continue with the reopening. Knowledge cannot be presumed without strict compliance. The court rejected the revenue's argument that reasons need only be furnished once, emphasizing the need for responsible conduct by the state. en-us Wed, 16 Sep 2015 00:00:00 +0530 Fri, 25 Jul 2025 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=264451 The HC held that failure to furnish reasons for reopening under Section 148 renders the reassessment order invalid. Recording and providing reasons is a jurisdictional requirement that must be strictly followed to prevent arbitrary reopening. The procedure allows the assessee to challenge the validity of the reasons before reassessment proceeds. The AO must consider objections and either withdraw or continue with the reopening. Knowledge cannot be presumed without strict compliance. The court rejected the revenue's argument that reasons need only be furnished once, emphasizing the need for responsible conduct by the state. Case-Laws Income Tax Wed, 16 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=264451