Reassessment validity depends on recorded reasons only; a different basis for the addition cannot sustain reopening.

Reassessment under sections 147 and 148 must stand or fall on the reasons recorded for reopening, and the Assessing Officer cannot substitute a different basis at the assessment stage. Here, the recorded reason referred to alleged receipt of an accommodation entry, but the addition was ultimately made on the footing that the assessee had provided accommodation entries and earned commission. Because the reassessment proceeded on a materially different foundation from the recorded reasons, the Tribunal held the jurisdiction to reopen was unsustainable. The reassessment was therefore treated as bad in law and without jurisdiction, and the Revenue's challenge to deletion of the addition failed.

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Issues: Whether reassessment under sections 147 and 148 was valid where the assessment was ultimately made on a ground different from the reason recorded for reopening.

Analysis: The recorded reason for reopening related to alleged receipt of an accommodation entry, while the addition in assessment was made on the basis that the assessee had provided accommodation entries and earned commission thereon. The Tribunal applied the settled principle that the validity of initiation of reassessment must be tested on the basis of the reasons recorded, and the Assessing Officer cannot improve upon, substitute, or supplant those reasons by invoking a different foundation for the addition. Since the reassessment proceeded on a materially different footing from the recorded reasons, the jurisdiction assumed under section 147 was held to be unsustainable.

Conclusion: The reassessment proceedings were held to be bad in law and without jurisdiction, and the Revenue's challenge to deletion of the addition failed.

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