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The requirement of recording the reasons, communicating the same to the assessee, enabling the assessee to file objections and the requirement of passing a speaking order are all designed to ensure that the Assessing Officer does not reopen assessments which have been finalized on his mere whim or fancy and that he does so only on the basis of lawful reasons.

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Sec. 147 of Income Tax Act, 1961— Reassessment —Reopening of assessment invalid as reasons recorded by the assessing officer produced before the honourable High Court are quite different as given to the assessee. - WIMCO SEEDLINGS LTD. V/s JT. CIT - [2020] 183 ITD 211 (ITAT-DELHI)