Dear Friends,
It is necessary to record reasons in writing by AO before the notice is issued u/s 148. The question is how the assessee can verify whether proper reasons have been recorded in writing before issuing notice u/s 148?
Also, what may be the proper reasons?
Thanks in advance,
Regards
Chintan
Dear Chintan,
It is absolute mandatory for AO to record reasons before issuing notice u/s 148. This thing is held by various judgements + Subsection 2 is very clear in using the term "shall"
After filing Return of Income in response to d notice the assesee can demand those reasons n if demamded AO is bound to furnish those to assessee.
Now coming to what constitute "proper" - It has nothing to do with any format, etc I mean no format/mammer is prescribed in which reasons should be recorded.
Only thing is it has to be concrete n not merely a gossip or an an estimate or an opinion...
thank u amirbhai......
AMIR IS ABSOLUTELY RIGHT.
I THINK U ATTENDED COACHING OF VINOD GUPTA SIR.
NOT NECESSAIRALY BUT I JUST THINK SO.
CAclubindia
