Reassessment scope cannot exceed recorded reasons; additions on unrelated transactions were unsustainable and deleted.

Reassessment under section 147 must remain confined to the reasons recorded for reopening, and the Assessing Officer cannot sustain additions on issues outside that jurisdictional basis. Where the recorded reasons referred to accommodation entries from specified entities but the assessment made additions for transactions with different entities not mentioned in those reasons, the reassessment exceeded the permissible scope. The addition on matters not covered by the recorded reasons was therefore unsustainable and was deleted in favour of the assessee.

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Issues: Whether additions made in reassessment proceedings could be sustained when they were based on issues not forming part of the reasons recorded for reopening the assessment under section 147.

Analysis: The reasons recorded for reopening referred to alleged accommodation entries received from specified entities, whereas the assessment order ultimately made additions on account of transactions with different entities not mentioned in those reasons. The reopening power under section 147 is confined to the basis on which jurisdiction is assumed, and the Assessing Officer cannot travel beyond the recorded reasons to make additions on unrelated items without a fresh jurisdictional basis. Since the additions were made on matters not connected with the recorded reasons, the reassessment exceeded the permissible scope of jurisdiction.

Conclusion: The addition made on issues not covered by the recorded reasons for reopening was unsustainable and was deleted in favour of the assessee.

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