Reassessment on already adjudicated digital material is impermissible without a fresh and independent basis for reopening.

Reassessment under the Income-tax Act cannot be initiated on the same seized digital material that was already used in earlier assessment proceedings and examined in appeal. Here, the reopening was based on a WhatsApp image that had formed the foundation of a section 153C addition, and that addition had already been deleted in appeal. Because the material had been fully considered and adjudicated earlier, the same facts could not support another round of reassessment without a fresh and independent basis. The impugned reopening notice and order were therefore unsustainable.

---

---

Issues: Whether reassessment proceedings under Sections 148A(3) and 148 of the Income-tax Act, 1961 could be initiated on the very same WhatsApp material that had already formed the basis of earlier assessment proceedings under Section 153C of the Act and had been dealt with in appeal.

Analysis: The reassessment notice was founded on the same seized digital material that had earlier been used for making an addition in the section 153C assessment. That addition had already been deleted in appeal. The material forming the basis of the impugned reopening thus stood examined and adjudicated upon in prior proceedings. In such a situation, reopening on the same foundation was not permissible, particularly when the amounts referred to in the reopening notice emanated from the same WhatsApp image already considered earlier. The digital material, without further corroboration, could not justify another round of reassessment on identical facts.

Conclusion: Reopening on the same material was impermissible and the impugned order and notice were unsustainable.

Ratio Decidendi: Reassessment cannot be initiated on the same material that has already been the subject of prior assessment and appellate adjudication, unless there is a fresh and independent basis for reopening.

---