Reassessment limited to escaped income; original loss computation cannot be reopened for broader recomputation.

Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 was confined to income that had escaped assessment and to recomputation of loss only within that limited statutory field. An assessee could not use valid reassessment proceedings to reopen the original assessment and seek recomputation of the entire loss determined earlier, merely because a larger loss had not been claimed at the original stage. The availability of rectification under section 35 reinforced that such mistakes were not meant to be corrected through section 34(1)(a). The assessee's wider recomputation claim was therefore rejected.

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Issues: Whether, in reassessment proceedings properly initiated under section 34(1)(a) of the Indian Income-tax Act, 1922, the assessee could reopen the original assessment and claim recomputation of the entire loss determined in the earlier final assessment.

Analysis: The power under section 34(1)(a) was held to be confined to assessing or reassessing the income that had escaped assessment and to recomputing loss only within the limited statutory field created by that provision. The omission to claim a larger loss in the original assessment did not permit reopening of the whole assessment in reassessment proceedings. The existence of section 35, which provides rectification of mistakes, reinforced the conclusion that such errors could not be pursued through section 34(1)(a). Earlier authorities were applied to hold that reassessment is limited to escaped income and does not authorise general recomputation of items already concluded in the original assessment.

Conclusion: The question was answered in the negative and the assessee's contention was rejected.

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