Reassessment jurisdiction under Section 147 cannot survive on unrelated additions when the recorded reasons fail and Explanation 3 does not widen power.

Reopening under Section 147 must rest on a valid jurisdictional basis, and Explanation 3 does not enlarge the Assessing Officer's power to sustain reassessment on issues unrelated to the recorded reasons. Where no addition is made on the grounds stated in the reassessment notice, additions on other issues cannot independently keep the reassessment alive. In cases where notice is issued beyond four years, the requirement that the assessee failed to disclose fully and truly all material facts remains material, and unrelated additions cannot be used to bypass that statutory threshold. The reassessment was therefore not sustainable on the unrelated additions, and the issue was decided in favour of the assessee.

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Issues: Whether, upon reopening an assessment, the Assessing Officer can make additions on issues not forming part of the recorded reasons when no addition is made on the grounds on which the reassessment notice was issued, and whether Explanation 3 to Section 147 enlarges that power.

Analysis: Reopening under Section 147 must be founded on a valid jurisdictional basis. Explanation 3 only clarifies the scope of the reassessment proceedings and does not enlarge the Assessing Officer's power so as to sustain reassessment where the very basis for reopening does not survive. Where notice is issued beyond four years, the statutory requirement of failure to disclose truly and fully all material facts remains material, and permitting reassessment to continue solely on unrelated issues would circumvent that requirement.

Conclusion: The reassessment could not be sustained merely on unrelated additions when no addition was made on the recorded reasons; the issue was decided in favour of the assessee.

Ratio Decidendi: Explanation 3 to Section 147 does not expand the Assessing Officer's jurisdiction beyond the reasons recorded for reopening, and a reassessment cannot be sustained solely on issues unrelated to the recorded basis when that basis fails.

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