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Whether the Tribunal was correct in holding that due process of law has been not been followed in reopening of the case by the AO when the reasons were recorded before issue of notice u/s. 148 of the IT Act 1961?

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Section 148 of the Income Tax Act, 1961 — Reassessment — Where notice under section 148 was issued prior to recording of reasons for reopening assessment, since notice being without jurisdiction, deserved to be quashed—Principal Commissioner of income tax vs. Tata Sons Ltd. [2019] 267 Taxman 13 (Bombay)

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