Reassessment under section 147(a) may cover section 147(b) items, with additions sustained in favour of the assessee.

Reassessment under section 147(a) of the Income-tax Act could include items otherwise falling under section 147(b), and the distinction between sections 147(a) and 147(b) did not require deletion of additions made under section 147(b). The Supreme Court answered both referred questions in favour of the assessee and against the Revenue, noting that the Revenue accepted this position on the facts and that the point was covered by the cited precedent.

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Issues: Whether, on the facts and circumstances of the case, reassessment under section 147(a) of the Income-tax Act, 1961 could include items otherwise falling under section 147(b), and whether the distinction between sections 147(a) and 147(b) required deletion of additions brought under section 147(b).

Analysis: The questions referred were answered on the factual matrix accepted by the parties. The Revenue fairly accepted that both questions had to be answered in favour of the assessee. The Court also noted that the same view had been taken in the cited precedent governing the point.

Conclusion: Both questions were answered in the affirmative in favour of the assessee and against the Revenue.

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