Reassessment must rest on the Assessing Officer's own satisfaction; additions outside recorded reasons cannot survive reopening.

Reassessment under Sections 147 and 148 must be founded on the Assessing Officer's own lawful satisfaction within the statutory time limits, and an appellate direction cannot by itself confer jurisdiction to reopen an assessment. Where the reopening is beyond limitation and the mandatory approval under Section 151 is absent, the notices and resulting assessments are void. The text also states that an addition cannot be sustained on a ground different from the recorded reasons for reopening when no addition is made on the original basis. On these principles, the reassessment for the earlier years was quashed and the later-year addition was deleted.

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Issues: (i) Whether reassessment notices issued under Section 148 for assessment years 1996-97 and 1997-98, based on directions of the appellate authority and without proper satisfaction of the Assessing Officer, were valid in law; (ii) Whether, for assessment year 1999-2000, an addition could be sustained on a ground not forming part of the reasons recorded for reopening, when no addition was made on the recorded basis.

Issue (i): Whether reassessment notices issued under Section 148 for assessment years 1996-97 and 1997-98, based on directions of the appellate authority and without proper satisfaction of the Assessing Officer, were valid in law.

Analysis: The reopening for the earlier assessment years was founded on a direction in the appellate order and was issued after the expiry of the ordinary limitation period. The governing principle applied was that a higher appellate authority cannot confer jurisdiction on the Assessing Officer to reopen an assessment beyond the limits prescribed by the Act, and that a direction of the appellate authority does not substitute the Assessing Officer's own satisfaction. The absence of prior statutory approval under Section 151 further showed non-compliance with the mandatory conditions for reopening.

Conclusion: The reassessment notices and the resulting assessments for assessment years 1996-97 and 1997-98 were held to be void ab initio and were quashed, in favour of the assessee.

Issue (ii): Whether, for assessment year 1999-2000, an addition could be sustained on a ground not forming part of the reasons recorded for reopening, when no addition was made on the recorded basis.

Analysis: The reopening for the relevant year was made on the stated belief that bank deposits represented escaped income, but the assessment ultimately made an addition only towards unexplained investment in construction. The principle applied was that if the very basis of reopening is not sustained in assessment, the Assessing Officer cannot independently sustain reassessment by making an addition on a different ground unrelated to the recorded reasons.

Conclusion: The addition made on the different ground was deleted, and the reopening issue was decided in favour of the assessee.

Final Conclusion: The Tribunal invalidated the reopening for the earlier years and deleted the addition for the later year, while leaving only academic and infructuous grounds undecided on merits, thereby granting substantial relief to the assessee.

Ratio Decidendi: Reassessment under Sections 147 and 148 must rest on the Assessing Officer's own lawful satisfaction within the statutory limits, and an addition cannot be sustained on a ground outside the recorded reasons if the original basis for reopening is not assessed.

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