https://www.taxtmi.com/caselaws?id=268000 Reopening of assessment requires the assessing officer to be prima facie satisfied about understatement of income before issuing a notice under Section 143(2); that notice is qualitatively different from a standard Section 142(1) notice and must inform the assessee why a return is sought. Reasons recorded for invoking reassessment under Section 147/148 must be communicated to the assessee, and participation in reassessment proceedings does not cure the mandatory requirement of a Section 143(2) notice. Consequently, reassessment orders passed without compliance with the mandatory pre-reassessment notice requirement are legally unsustainable. en-us Wed, 04 Nov 2015 00:00:00 +0530 Thu, 15 Jan 2026 14:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=268000 Reopening of assessment requires the assessing officer to be prima facie satisfied about understatement of income before issuing a notice under Section 143(2); that notice is qualitatively different from a standard Section 142(1) notice and must inform the assessee why a return is sought. Reasons recorded for invoking reassessment under Section 147/148 must be communicated to the assessee, and participation in reassessment proceedings does not cure the mandatory requirement of a Section 143(2) notice. Consequently, reassessment orders passed without compliance with the mandatory pre-reassessment notice requirement are legally unsustainable. Case-Laws Income Tax Wed, 04 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=268000