https://www.taxtmi.com/caselaws?id=40259 Where a taxpayer challenges reopening under s.147 by alleging that reasons under s.148 were neither recorded nor disclosed, the court is obliged to call for and examine the recorded reasons, which are ordinarily produced in the revenue's reply; the HC erred in summarily dismissing the writ without such scrutiny, so the dismissal was set aside and the writ restored for decision on merits. Further, once a first s.148 notice had been served and complied with by filing a return, the taxpayer was entitled to contend that a second notice was impermissible and, in any event, time-barred; these contentions were directed to be considered on merits. The appeal was allowed and the matter remitted for expeditious disposal. en-us Fri, 28 Jul 2000 00:00:00 +0530 Sun, 04 Jan 2026 13:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=40259 Where a taxpayer challenges reopening under s.147 by alleging that reasons under s.148 were neither recorded nor disclosed, the court is obliged to call for and examine the recorded reasons, which are ordinarily produced in the revenue's reply; the HC erred in summarily dismissing the writ without such scrutiny, so the dismissal was set aside and the writ restored for decision on merits. Further, once a first s.148 notice had been served and complied with by filing a return, the taxpayer was entitled to contend that a second notice was impermissible and, in any event, time-barred; these contentions were directed to be considered on merits. The appeal was allowed and the matter remitted for expeditious disposal. Case-Laws Income Tax Fri, 28 Jul 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=40259