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Court Remands Case for Lack of Recorded Reasons in Tax Reassessment; Authorities Must Justify Actions Even Briefly.
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....Validity of reassessment proceedings - order passed u/s 148A(d) - the High Court observed that, While affirming the proposal in the show cause notice, the authorities are expected to record reasons, at least brief reasons, and if not brief reasons, as to why the proposal in the show cause notice is to be confirmed despite the assessee submitting the reply. - Since even in an ex parte proceedings, the authority has to record reasons for coming to a conclusion as to why the case has been taken out for re-opening of the assessment. - The HC restored back the matter before the AO to the stage of the show cause notice u/s 148A(b).....