Reassessment fails without a live nexus between recorded reasons and final addition; unrelated grounds cannot sustain reopening.

Reassessment requires a valid notice and a live nexus between the recorded reasons for reopening and the addition made in the assessment. Where the proceedings were initiated on alleged undisclosed suspicious transactions, but the final assessment brought to tax a different deemed-income basis, the assumption of jurisdiction failed because no addition was made on the original recorded ground. An Assessing Officer cannot sustain reassessment on an unrelated basis after reopening. The reopening under section 148A(d) read with section 147 was therefore invalid and the reassessment order was quashed in favour of the assessee.

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Issues: Whether reassessment was valid where the notice was issued on one recorded reason but the addition was made on a different ground.

Analysis: The reassessment was initiated on the basis of alleged undisclosed suspicious transactions of Rs. 49,69,671, but the assessment order ultimately brought to tax a different amount as deemed income under section 172(2). A reassessment proceeding must rest on a valid notice and a live nexus between the recorded reasons and the jurisdiction assumed. Where no addition is made on the very ground forming the basis of reopening, the assumption of jurisdiction fails, and the Assessing Officer cannot sustain the reassessment by introducing an unrelated basis for addition.

Conclusion: The reopening under section 148A(d) read with section 147 was invalid and the reassessment order was quashed, in favour of the assessee.

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