Reassessment reopening fails when no addition is made on the recorded reason for issuing notice and the basis for reopening disappears.

Reassessment initiated on a recorded reason alleging understatement of sale consideration for immovable property could not be sustained where no addition was made on that very ground in the completed reassessment. The reassessment instead proceeded on a different purchase-related addition, so the original basis for reopening did not survive. On that footing, the reopening under sections 147 and 148 was held unsustainable in law, and the assessee succeeded.

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Issues: Whether reassessment initiated under sections 147 and 148 of the Income-tax Act, 1961 was valid when no addition was made on the sole ground recorded for reopening.

Analysis: The reassessment was based on one recorded reason concerning alleged understatement of sale consideration of immovable property. In the reassessment order, no addition was ultimately made on that very ground, and instead a different purchase-related addition was made. Once the basis for reopening did not survive in the completed reassessment, the reopening could not be sustained.

Conclusion: The reopening was held unsustainable in law, and the assessee succeeded.

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