Dismissing the appeal of the revenue the Court held that ; even before recording reasons  on 31 st March 2010, under his signature, a notice u/s. 148 was already issued on 30^th March, 2010, therefore Tribunal was right in holding that even if case made out in affidavit belatedly filed by AO was correct, it would not advance case of revenue.  Court observed that   the process of recording reasons as per mandate of Sub-Section (2) of S. 148 was completed when AO signed reasons on 31^st March, 2010, thus, even before recording reasons under his signature, a notice u/s. 148 was already issued on 30^th March, 2010, therefore  reassessment was held to be bad in law .