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“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

Ashish Girish Jain, Mumbai vs. ITO, Ward 42(1)(1), Mumbai

ITA 5328/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh ShahFor Respondent: Shri Pradipsinh Saktavat
Section 132Section 143(1)Section 143(3)Section 147Section 148

return filed in response to the notice issued under Section 148 of the Act. No objections were filed by the Assessee challenging the reasons recorded for reopening the assessment. The Assessing Officer proceeded with reassessment proceedings. It was noticed by the Assessing Officer that in the Balance Sheet ... income has escaped assessment is that the AO should have tangible information which the AO was having being received from Investigation wing. Admittedly, the reasons recorded were given to the appellant during assessment proceedings. It is also admitted that the appellant had not raised a any objections against such reasons

M/S Jhs Svendgaard Laboratories Ltd., New Delhi vs. DCIT CC-31, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

effort to co-relate with the information to the actual business transaction of the Assessee. The Ld. Counsel has also taken us through the reasons recorded in the notice issued u/s 148A(b) of the Act and submitted that A.O. has merely reproduced information without verifying its accuracy ... form an independent belief founded on relevant and verifiable material that bears a live link with the alleged undisclosed income. The reasons recorded in the notice issued under Section 148A(b) of the Act clearly reflects that the AO merely reproduced the generalized information without verifying its accuracy or relevance

Bholenath Foods Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle- 4(2), New Delhi

The appeal of the assessee is disposed of in above terms

ITA 5777/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Jan 2026AY 2012-13

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwalassessment Year : 2012-13 Bholenath Foods Limited, Vs. Income Tax Officer, Shop No.208, Ward 47(1), Bldg. No.2612/13, Naya Bazar, New Delhi. Delhi – 110 006. Pan: Aabcb3842P

For Appellant: Shri Shivam Yadav, Advocate &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 250Section 68

after taking approval of the PCIT. The assessee filed ITR in response to notice u/s 148 and asked for the copy of the reasons recorded which was provided to the assessee. Subsequently, notices u/s 143(2) dated 12.11.2019 was issued and a notice u/s 142(1) was also issued from

Nareshkumar Gokalchand Lodha, Mumbai vs. The Income Tax Officer Ward 2(3)(8), Surat

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 834/SRT/2023[2012-13]Status: DisposedITAT Surat06 Jan 2026AY 2012-13

Bench: Shri Sandeep Gosain, () & Shri Om Prakash Kant, ()

Section 144Section 148Section 151Section 250Section 68Section 69

Statutory notice as required u/s 148 is bad in law. 3. The assessment order passed u/s 144 r.w.s. 147 without providing copy of reasons recorded if any before issuing the notice u/s 148 if any is bad in law. 4. The assessment order passed u/s 144 r.w.s

Nareshkumar Gokalchand Lodha, Mumbai vs. The Income Tax Officer Ward 2(3)(8), Surat

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 833/SRT/2023[2010-11]Status: DisposedITAT Surat06 Jan 2026AY 2010-11

Bench: Shri Sandeep Gosain, () & Shri Om Prakash Kant, ()

Section 144Section 148Section 151Section 250Section 68Section 69

Statutory notice as required u/s 148 is bad in law. 3. The assessment order passed u/s 144 r.w.s. 147 without providing copy of reasons recorded if any before issuing the notice u/s 148 if any is bad in law. 4. The assessment order passed u/s 144 r.w.s

Nareshkumar Gokalchand Lodha, Mumbai vs. ITO Ward 2(3)(8), Surat

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 832/SRT/2023[2010-11]Status: DisposedITAT Surat06 Jan 2026AY 2010-11

Bench: Shri Sandeep Gosain, () & Shri Om Prakash Kant, ()

Section 144Section 148Section 151Section 250Section 68Section 69

Statutory notice as required u/s 148 is bad in law. 3. The assessment order passed u/s 144 r.w.s. 147 without providing copy of reasons recorded if any before issuing the notice u/s 148 if any is bad in law. 4. The assessment order passed u/s 144 r.w.s

Nareshkumar Gokalchand Lodha, Mumbai vs. The Income Tax Officer Ward 2(3)(8), Surat

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 831/SRT/2023[2010-11]Status: DisposedITAT Surat06 Jan 2026AY 2010-11

Bench: Shri Sandeep Gosain, () & Shri Om Prakash Kant, ()

Section 144Section 148Section 151Section 250Section 68Section 69

Statutory notice as required u/s 148 is bad in law. 3. The assessment order passed u/s 144 r.w.s. 147 without providing copy of reasons recorded if any before issuing the notice u/s 148 if any is bad in law. 4. The assessment order passed u/s 144 r.w.s

Nareshkumar Gokalchand Lodha, Mumbai vs. ITO Ward 2(3)(8), Surat

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 830/SRT/2023[2009-10]Status: DisposedITAT Surat06 Jan 2026AY 2009-10

Bench: Shri Sandeep Gosain, () & Shri Om Prakash Kant, ()

Section 144Section 148Section 151Section 250Section 68Section 69

Statutory notice as required u/s 148 is bad in law. 3. The assessment order passed u/s 144 r.w.s. 147 without providing copy of reasons recorded if any before issuing the notice u/s 148 if any is bad in law. 4. The assessment order passed u/s 144 r.w.s

Nareshkumar Gokalchand Lodha, Mumbai vs. ITO Ward 2(3)(8), Surat

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 829/SRT/2023[2008-09]Status: DisposedITAT Surat06 Jan 2026AY 2008-09

Bench: Shri Sandeep Gosain, () & Shri Om Prakash Kant, ()

Section 144Section 148Section 151Section 250Section 68Section 69

Statutory notice as required u/s 148 is bad in law. 3. The assessment order passed u/s 144 r.w.s. 147 without providing copy of reasons recorded if any before issuing the notice u/s 148 if any is bad in law. 4. The assessment order passed u/s 144 r.w.s

Nareshkumar Gokalchand Lodha, Mumbai vs. ITO 2(3)(8), Surat

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 828/SRT/2023[2008-09]Status: DisposedITAT Surat06 Jan 2026AY 2008-09

Bench: Shri Sandeep Gosain, () & Shri Om Prakash Kant, ()

Section 144Section 148Section 151Section 250Section 68Section 69

Statutory notice as required u/s 148 is bad in law. 3. The assessment order passed u/s 144 r.w.s. 147 without providing copy of reasons recorded if any before issuing the notice u/s 148 if any is bad in law. 4. The assessment order passed u/s 144 r.w.s

Pradeep Kumar Narsaria, Ranchi vs. ITO, Ward 2(1), Ranchi

In the result, this appeal of the assessee is partly allowed for statistical purposes

ITA 65/RAN/2025[2015-16]Status: DisposedITAT Ranchi06 Jan 2026AY 2015-16

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaypradeep Kumar Narsaria, I.T.O., Opp. Income Tax Colony, H.B. Road, Ward-2(1), Vs. Lalpur, Ranchi-834001. Ranchi. Pan No. Aakpn 8455 G Appellant/ Assessee Respondent/ Revenue

cash deposit in the savings bank account of the assessee with the State Bank of India. It was a submission that the reasons recorded for the reopening are invalid and the assessment is liable to be quashed. The ld. AR has placed before us the copy of his current account ... left open. 6. We have considered the rival submissions. A perusal of the facts in the present case clearly shows that in the reasons recorded, admittedly the Assessing Officer has referred to the bank account number of the savings bank account but the transactions from the Current Account maintained with

Smita, Ranchi vs. ITO Ward 3(4), Chaibasa

The appeal of the assessee is allowed

ITA 266/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 144BSection 147Section 148Section 151

notice under section 148 was issued, the mandatory approval under section 151 of the Act was never supplied to the assessee along with the reasons recorded. From the assessment order also, it is evident that no copy of approval under section 151 of the Act was furnished or served upon ... categorically held that approval under section 151 of the Act is a mandatory requirement and must be furnished to the assessee along with the reasons recorded, failing which the reassessment proceedings become invalid. Similarly, the coordinate bench of the Tribunal in Sunil Kumar Jain vs. ITO (ITA No. 2429/Del/2023) held

Naveen Singh, Jamshedpur vs. Deputy Commissioner of Income Tax, Circle - 1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

evoke any response. Accordingly, the AO completed the assessment under section 147 read with section 144, based on material available on record. The reasons recorded for reopening under section 147 were that information was received from the Director of Income Tax (Investigation), Patna, that the assessee had purchased an immovable ... evidence in support thereof and without any independent application of mind on the issue. It is an inalienable principle of law that the reasons recorded u/s. 148 of the Act should be based on credible material which must have a live link or nexus with the belief that there

Bishnu Transport Company, Dhanbad vs. DCIT/ACIT, Circle-1, Dhanbad

In the result, the appeal of the assessee is allowed

ITA 401/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 147Section 148Section 151Section 151oSection 68

section 148 of the Act, the Assessing Officer must obtain prior sanction of the specified authority, who must apply its independent mind to the reasons recorded and form satisfaction that it is a fit case for reopening. The satisfaction contemplated under section 151 of the act is not an empty

Jitendrakumar Dahyalal Parmar, Deesa vs. The ITO, Ward-2, Palanpur

In the result, the appeal of the assessee is allowed

ITA 943/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad06 Jan 2026AY 2011-12

Bench: Ms. Suchitra Kambleassessment Year 2011-12

For Appellant: Shri Mehul Thakker, C.AFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 132Section 147Section 148Section 44Section 44A

assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee 5. The ld. A.R. submitted that the reasons recorded identical to that of assessee’s sister concern and also pointed out page 59 to 60 wherein the figures are also identical to that ... bogus expenses without making any payment as I.T.A No. 943/Ahd/2025 Jitendrakumar Dahyalal Parmar, A.Y. 2011-12 such. The ld. D.R. further submitted that the reasons recorded are independent and are not identical to that of other cases. 7. Heard both the parties and perused all the material available on record

Shah Mahendrakumar Mafatlal (HUF), Mithkhali vs. Income Tax Officer, Ward 1(1)(3), Ahmedabad

In the result, the appeal of the assessee for A

ITA 1689/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad06 Jan 2026AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1688 & 1689/Ahd/2025 (िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16) बनाम/ Shah Mahendrakumar Income Tax Officer Mafatlal Huf Ward-1(1)(3), Vs. 27D, Maharashtra Society, Ahmedabad Anmol Mithkhali Owners Asso Mithkhali, Ellisbridge, Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaihs8263H (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Sulabh Padshah, Ar ""यथ" क" ओर से/Respondent By : Shri Yogesh Mishra, Sr. Dr 16/12/2025 Date Of Hearing Date Of Pronouncement 06/01/2026

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147

Appeals) has erred in upholding the action of AO reopening the case of Appellant without any basis or justification. It is submitted that the reasons recorded itself is Incorrect, formed relying upon Incorrect information with incorrect assumption of fictitious loan transactions and it has no nexus or relevance with Appellant

Shah Mahendrakumar Mafatlal (HUF), Mithkhali vs. Income Tax Officer, Ward 1(1)(3), Ahmedabad

In the result, the appeal of the assessee for A

ITA 1688/AHD/2025[ 2014-15]Status: DisposedITAT Ahmedabad06 Jan 2026

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1688 & 1689/Ahd/2025 (िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16) बनाम/ Shah Mahendrakumar Income Tax Officer Mafatlal Huf Ward-1(1)(3), Vs. 27D, Maharashtra Society, Ahmedabad Anmol Mithkhali Owners Asso Mithkhali, Ellisbridge, Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaihs8263H (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Sulabh Padshah, Ar ""यथ" क" ओर से/Respondent By : Shri Yogesh Mishra, Sr. Dr 16/12/2025 Date Of Hearing Date Of Pronouncement 06/01/2026

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147

Appeals) has erred in upholding the action of AO reopening the case of Appellant without any basis or justification. It is submitted that the reasons recorded itself is Incorrect, formed relying upon Incorrect information with incorrect assumption of fictitious loan transactions and it has no nexus or relevance with Appellant

Jap Overseas Private Limited, Mumbai vs. ITO Ward, 10 (2)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 7228/MUM/2025[2010 - 11]Status: DisposedITAT Mumbai06 Jan 2026

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethjap Overseas Private Vs. Ito Ward, 10(2)(1) Limited Room No. 573, Aayakar Bhawan, B-102, Twinkle Maharishi Karve Road, New Marine Lines, Apartments, New Link Mumbai-400020. Road, Lokhandwala Complex, Andheri (W), Mumbai-400053. Pan/Gir No: Aaacj1573C (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 69C

commencing the assessment proceedings by issue of notices u/s 143(2) & u/s 142(1) of the Act without first furnishing the reasons recorded and without waiting for the disposal of objections that may be raised to the reasons recorded. 2.i. In doing so, he decided the issue by relying ... erred in dismissing Gr. No. 3 raised before him challenging the order of the AO of rejecting objections raised to the reasons recorded. 3.i. In doing so, he did not appreciate that the ITO in the said order did not at all deal with the objections that were actually

Jigna Ashutosh Bhatt, Mumbai vs. Income Tax Officer Ward 33(2)(1), Mumbai

In the result the appeal of the assessee is partly allowed on merits

ITA 3639/MUM/2025[2011-12]Status: HeardITAT Mumbai06 Jan 2026AY 2011-12

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarito Ward-32(2)(1) Jigna Ashutosh Bhatt Kautilya Bhavan, I-1434, Govardhan Nagar Bandra Kurla Bldg. No. 4, Opp. Poinsur Vs. Complex, Bandra (E), Gymkhana, Kandivali Mumbai-400 051 (West), Mumbai-400 067 Pan/Gir No. Aiypb4411G (Applicant) (Respondent) Assessee By Shri Ketan L. Vajani, Ld. Ar Revenue By Shri Aditya Rai, Ld. Dr Date Of Hearing 05.01.2026 Date Of Pronouncement 06.01.2026

Section 132(4)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68

assessee, is completely absent, and therefore the addition made thereunder is legally unsustainable. 11. The learned AR also pointed out a discrepancy in the reasons recorded for reopening, wherein the name of the assessee is mentioned as “Jigna Ashok Bhatt”, whereas the correct name of the assessee is “Jigna Ashutosh ... fact received any cash loan from M/s Evergreen Enterprises. We also noted that there is a discrepancy in the name mentioned in the reasons recorded for reopening, wherein the name appears as “Jigna Ashok Bhatt”, whereas the correct name of the assessee is “Jigna Ashutosh Bhatt”, which further reflects lack

Pankaj Jindal Contractor, Mansa vs. The Deputy Commissioner of Income Tax, Circle-I, Bathinda

In the result the appeal of the assessee is allowed

ITA 695/ASR/2024[2014-15]Status: DisposedITAT Amritsar05 Jan 2026AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 695/Asr/2024 Assessment Year: 2014-15 M/S Pankaj Jindal Contractor, Vs. Dcit-Circle-1, Near Vidya Bharti School, Bathinda. Mansa. [Pan:-Aajfp8008L] (Appellant) (Respondent) Appellant By Sh. Sudhir Sehgal, Adv. Respondent By Sh. Charan Dass, Sr. Dr

Section 139(1)Section 143(3)Section 147Section 148Section 148aSection 250Section 282Section 40A(3)Section 68

because the proceedings-initiated u/s 147/148 of the Act are void ab initio as the copy of reasons recorded by the AO to initiate the proceedings were not provided to the assessee. 6. That the Ld. CIT(A) NFAC has erred on facts and law in dismissing the appeal ... Commissioner of Income-tax vs. V. Ramaiah [2019] 103 taxmann.com 202 (SC) Where High Court upheld Tribunal's order quashing reassessment proceedings ground that reasons recorded by assessing authority for reopening assessment were never communicated to assessee, SLP filed against said decision was to be dismissed iii. Baldev Singh Giani