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2001 (12) TMI 21 - HC - Income TaxReassessment, Reason To Believe - we find that the Assessing Officer has in fact recorded reasons on August 31, 1999, for issuing notice under section 148(1). We may say that the reasons mentioned by him do not suffer from any infirmity. The belief entertained by the Assessing Officer is clearly based on reasons which have bearing on the matter. – Further, Sub-section (2) of section 148 clearly provides that the Assessing Officer shall, before issuing any notice thereunder record his reasons for doing so. We have already held above that the Assessing Officer has recorded necessary reasons in support of the belief. The question is whether an assessee can demand a copy of the Assessing Officer's reasons along with the notice. The proceedings in the back assessment begin only with the issue of notice under section 148. It is only after the service of notice, the assessee becomes a party to the proceedings. Consequently, the assessee is not entitled to get copy of the same at the stage of issuance of notice. In the result, the writ application deserves dismissal. We order accordingly.
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