Yes, the understanding is correct that if the notice is not accompanied with the reasons within the specified time frame (i.e. 4 or 6 years) then in such case the reassessment proceedings can be termed as invalid.
In this regard a reference can be made to GKN driveshaft 259 ITR 19 where in the apex court has referred a set procedure to be followed. Further the Delhi High court in Haryana Acrylic (2009) 308 ITR 38 has firmly held that where the reasons were not supplied with in 4 years ( time period as per the facts of the case) the reassessment was invalid. The same view has been followed by the Delhi ITAT in a recent judgment of Sri Balwant Rai Wadhwa ITA No.4806/Del/2010.
Hope this clarifies you.
In this regard a reference can be made to GKN driveshaft 259 ITR 19 where in the apex court has referred a set procedure to be followed. Further the Delhi High court in Haryana Acrylic (2009) 308 ITR 38 has firmly held that where the reasons were not supplied with in 4 years ( time period as per the facts of the case) the reassessment was invalid. The same view has been followed by the Delhi ITAT in a recent judgment of Sri Balwant Rai Wadhwa ITA No.4806/Del/2010.
Hope this clarifies you.