https://www.taxtmi.com/caselaws?id=21890 The court held that the recording of reasons under section 148(2) of the Income-tax Act is mandatory but does not require immediate communication to the assessee along with the notice under section 148(1). The assessee must file the return first and can challenge the reassessment validity, prompting the Assessing Officer to disclose the reasons. This decision balances the need to protect sources and informants with the assessee's right to a fair hearing. The court emphasized the importance of the Assessing Officer's subjective satisfaction and relevant material in the reassessment process. en-us Wed, 27 Mar 1991 00:00:00 +0530 Wed, 02 Dec 2009 18:21:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21890 The court held that the recording of reasons under section 148(2) of the Income-tax Act is mandatory but does not require immediate communication to the assessee along with the notice under section 148(1). The assessee must file the return first and can challenge the reassessment validity, prompting the Assessing Officer to disclose the reasons. This decision balances the need to protect sources and informants with the assessee's right to a fair hearing. The court emphasized the importance of the Assessing Officer's subjective satisfaction and relevant material in the reassessment process. Case-Laws Income Tax Wed, 27 Mar 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21890