Once the initiation of reassessment proceedings had been challenged, all the grounds incidental thereto were available to assessee to challenge the validity of reassessment proceedings, hence, reassessment proceedings initiated by the Assessing Officer were not in conformity with the provisions of the first proviso to Section 147 of the Act. It was for Assessing Officer to record reasons clearly and unambiguously and no inference can be drawn therefrom.  That the requirement of the provisions of first proviso to Section 147 as well as Section 149(1)(b) of the Act were not fulfilled. Therefore, the reassessment proceedings under Section 147 were set aside as bad in law. Followed: Hindustan Lever Ltd. (2024) 268 ITR 332 (Bom.)(AY. 2005 -06)