https://www.taxtmi.com/caselaws?id=330351 Reopening under s.147 was challenged on the ground that the recorded "reasons to believe" were not supplied. Applying SC law in GKN Driveshafts, the Tribunal held the AO is duty-bound to furnish the recorded reasons within a reasonable time to enable objections to reassessment. On the evidence, the assessee repeatedly sought the reasons, but the AO did not provide them; the Revenue could not substantiate that reasons were ever furnished, and departmental "general practice" could not substitute proof of supply. Consequently, the reassessment framed under s.147 was held unsustainable and was quashed, granting relief to the assessee. en-us Mon, 16 May 2016 00:00:00 +0530 Tue, 06 Jan 2026 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330351 Reopening under s.147 was challenged on the ground that the recorded "reasons to believe" were not supplied. Applying SC law in GKN Driveshafts, the Tribunal held the AO is duty-bound to furnish the recorded reasons within a reasonable time to enable objections to reassessment. On the evidence, the assessee repeatedly sought the reasons, but the AO did not provide them; the Revenue could not substantiate that reasons were ever furnished, and departmental "general practice" could not substitute proof of supply. Consequently, the reassessment framed under s.147 was held unsustainable and was quashed, granting relief to the assessee. Case-Laws Income Tax Mon, 16 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330351