Allowing the petition the Court held that , recording of reasons is a mandatory requirement before the Assessing Officer can issue notice for reopening an assessment . The notice must succeed or fail on the basis of reasons so recorded and the Assessing Officer cannot supply reasons from any material or grounds outside the reasons recorded by him .Court observed that at all stages the Assessing Officer exhibited absolute non-application of mind to the facts and materials on record . The notice for reopening of assessment was therefore , based on reasons which were the product of such non -application of mind . Accordingly the notice was quashed . ( AY.2009-10)