1 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.670 OF 2007 The Commissioner of Income Tax-23. ...Appellant vs. Shri.Puransingh L.Manchanda. ...Respondent. --- Mr.Abhay Ahuja, for appellant. CORAM: D.K.DESHMUKH & J.P.DEVADHAR, JJ. DATED: 21st October,2008. P.C.:- 1. Admittedly, the reasons recorded for reopening the assessment were neither produced before the adjudicating authority nor before the CIT appeal nor before the Tribunal. When the assessee had specifically sought for a copy of the reasons recorded for reopening the assessment to the 2 assessing officer, he intimated that such reasons are discussed in the assessment order. Since the assessment order does not contain any reasons for reopening of the assessment, the Tribunal concluded that the assessing officer did not record any reasons for issuance of notice under section 148 of the Income Tax Act which is mandatory requirement before issuing notice under section 148 of the Act. In this view of the matter the finding recorded by the Tribunal that in the absence of reasons recorded proceedings initiated u/s 147 by issue of notice u/s.148 shall be rendered null and void, cannot be faulted. The appeal is dismissed. (D.K.DESHMUKH, J.) (J.P.DEVADHAR, J.)