Dismissing the appeal of the revenue the Court held that ,it is incumbent upon the assessing authority to record the reasons on record, while invoking these powers of reassessment and only then issue formal notice under section 148 requiring the assessee to file fresh returns in accordance with law. Notice issued without recording the reasons is held to be bad in law . (AY.1997-98)
Dy.CIT v. Gay Travels P. Ltd. (2020) 424 ITR 376 (Mad)(HC)
S.148: Reassessment — Notice —Reasons not recorded- Notice is held to be not valid [ S.147 ]