Reassessment under Section 147 is limited to escaped income and cannot reopen completed issues from the original assessment.

Reassessment under Section 147 is confined to escaped or under-assessed income and does not authorise a fresh review of the entire original assessment. Where reopening is initiated on one escaped item, completed matters that have already attained finality cannot be reconsidered merely because reassessment proceedings have begun. The Assessing Officer may bring the escaped income to tax, but cannot reopen concluded issues unrelated to that item or convert reassessment into a revision of the original assessment.

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Issues: Whether, after reopening an assessment under Section 147 of the Income-tax Act, 1961, the Assessing Officer can reassess only the escaped item or can also reopen and reconsider all other completed items of the original assessment.

Analysis: Reassessment under Section 147 is a machinery provision intended to bring to tax income that has escaped assessment. The reopening does not wipe out the original assessment in its entirety. Only the escaped income or under-assessed income falls within the reassessment jurisdiction, and the Assessing Officer cannot convert reassessment into a fresh review or revision of matters already concluded in the original assessment. The principle stated in earlier authority was confined to the escaped assessment and does not permit re-agitation of final issues unrelated to the escaped item.

Conclusion: The Assessing Officer cannot reopen the whole assessment and reconsider other concluded items merely because proceedings under Section 147 have been initiated on one escaped item.

Ratio Decidendi: Reassessment under Section 147 is confined to escaped income and does not authorise reopening of the entire assessment or reconsideration of matters that attained finality in the original assessment.

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