Belated Service of Reasons to believe Can Make Reassessment Proceeding bad in law


No reassessment notice under section 148 of the Income Tax Act can be issued unless the reasons to believe is noted by the assessing officer. Then, no reassessment proceeding can start without service of notice on the assessee . The law provides time limit within which the notice u/s 148 can be served on the assessee.The issue is whether when the A.O issues and serve notice u/s 148 on the assessee well within the time , but fails to supply the “reasons to believe” within the time , is the service of notice u/s 148 was proper.

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