The assessee filed writ petition challenging validity of reassessment proceedings on ground that Assessing Officer did not record detailed reasons for reopening of assessment. The reasons supplied to the assessee and reasons brought on record by revenue authorities were altogether different, validity of reassessment proceedings could not be upheld and, thus, said proceedings deserved to be quashed. (AY. 1989-90 to 1991-92)
Wimco Seedlings Ltd. v. JCIT (2020) 82 ITR 235 / 183 ITD 211 (Delhi)(Trib.)
S. 148 : Reassessment-Notice-Recorded reasons-Failure to provide complete details of reasons recorded and not merely few extracts of said reasons-Reassessment is held to be bad in law. [S. 147]