Reassessment without additions becomes academic when no live substantial question of law survives, leading to dismissal.

Where reassessment under Sections 153A and 153C resulted in no additions to the returned loss, the challenge to cancellation of that reassessment became academic. The Court noted that, in the absence of any live issue arising from the reassessment order, no substantial question of law survived for consideration. The appeal was therefore dismissed on the merits urged.

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Issues: Whether the reassessment framed under Section 153C read with Section 153A of the Income-tax Act was liable to be disturbed when no additions were made in the reassessment proceedings, and whether any substantial question of law arose.

Analysis: The Revenue's challenge was directed against the concurrent finding that the reassessment had resulted in no additions to the returned loss. In that situation, the challenge to the cancellation of the reassessment order was treated as academic. The Court also noted that the appeal did not raise any live substantial question of law for consideration.

Conclusion: The appeal was held not maintainable on the merits urged and was dismissed.

Ratio Decidendi: Where reassessment proceedings under Sections 153A and 153C culminate in no addition, the challenge to their cancellation becomes academic and no substantial question of law arises.

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