Reassessment jurisdiction fails when no addition is made on the recorded reopening reason and a different issue is added instead.

Reassessment under section 147 must stand or fall on the specific escapement reason recorded for reopening, and the Assessing Officer cannot sustain jurisdiction by making an addition on an unrecorded issue. Here, the reopening was based on an alleged accommodation entry from one concern, but no addition was made on that recorded ground in the assessment order; the only addition related to a different concern not mentioned in the reasons. On these facts, the reassessment lacked a valid jurisdictional foundation and was quashed, with the assessee's appeal succeeding.

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Issues: Whether the reassessment under section 147 was sustainable when no addition was made on the very escapement reason recorded for reopening, and whether addition on an unrecorded issue could be made independently.

Analysis: The reopening was founded on the alleged accommodation entry from one named concern in the recorded reasons. The assessment order, however, made no addition on that very issue. The later addition related to a different concern that did not figure in the recorded reasons. A reassessment can proceed only on the foundation of the recorded belief of escapement, and where that foundation fails because no addition is made on the recorded reason, the reassessment jurisdiction cannot be sustained for an altogether different issue.

Conclusion: The reassessment was invalid and was quashed; the issue is decided in favour of the assessee.

Final Conclusion: The assessee's appeal succeeded and the reassessment proceedings were annulled for want of sustainable jurisdiction.

Ratio Decidendi: Where reassessment is initiated on a specific recorded reason, but no addition is made on that very reason, the Assessing Officer cannot independently sustain the reassessment by making addition on another unrecorded issue.

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