Reassessment must match the recorded reason for reopening; no addition on that issue made the reassessment unsustainable.

Reassessment under sections 147 and 148 must remain linked to the specific income stated in the recorded reasons for reopening. Here, the reopening was based on alleged accommodation entries, but the assessment order made no addition on that very issue and instead dealt only with other matters. Because the jurisdictional basis for reassessment was not supported by any addition on the recorded reason, the reassessment could not be sustained. The reassessment order was quashed.

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Issues: Whether the reassessment and resulting assessment could be sustained when no addition was made on the very issue recorded as the reason for reopening under section 147 of the Income-tax Act, 1961.

Analysis: The reassessment was initiated on the premise that the assessee had received accommodation entries. The assessment order, however, did not make any addition on that recorded reason and proceeded only on other items. In such a situation, the reassessment could not be upheld, because the jurisdiction assumed under sections 147 and 148 must be tied to the income believed to have escaped assessment on the basis of the recorded reasons.

Conclusion: The reassessment order was quashed and the appeal was allowed.

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