Reassessment appeal scope limits challenge to concluded additions already upheld in original assessment proceedings.

An assessee cannot, in an appeal against a reassessment under section 147(b), challenge an addition already made in the original assessment under section 143(3) and sustained in earlier appeal. The reassessment is confined to income escaping assessment and does not permit reopening concluded items unrelated to that escapement. Where the disputed addition had already formed part of the original assessment and had travelled through the appellate process, it remained outside the permissible scope of the reassessment appeal. The issue was answered against the assessee and in favour of the Revenue.

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Issues: Whether an assessee can, in an appeal against a reassessment under section 147(b) of the Income-tax Act, 1961, challenge an addition that had already been made in the original assessment under section 143(3) and confirmed in appeal.

Analysis: The reassessment was confined to income escaping assessment and not to a review of concluded items unconnected with that escapement. An addition made in the original assessment and already carried through the appellate process could not be reopened in the appeal against reassessment merely because the original assessment had been superseded for other purposes. The assessee's grievance lay outside the permissible scope of the reassessment appeal.

Conclusion: The question was answered against the assessee and in favour of the Revenue.

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