Reassessment limits bar taxpayers from reducing income voluntarily offered earlier through a revised claim in reassessment proceedings.

Reassessment under section 147 is described as a mechanism to bring escaped income to tax, not to reopen or revise matters already concluded at the assessee's instance. The note explains that where higher income from house property was voluntarily disclosed in the original return, it cannot later be reduced in a reassessment return by claiming that part of the rental receipts belonged to the spouse or represented the spouse's share in jointly owned property. On that reasoning, the originally offered income remained binding in reassessment, and the addition sustained by the lower authorities was upheld.

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Issues: Whether the assessee was entitled, in reassessment proceedings initiated under section 147 read with section 148 of the Income-tax Act, 1961, to reduce the income from house property originally disclosed in the return filed under section 139(1) on the ground that the higher disclosure was allegedly inadvertent and related partly to the spouse's share.

Analysis: The assessee had voluntarily disclosed the higher house property income in the original return. In the reassessment return, the disclosure was reduced on the plea that certain rental receipts belonged to the spouse or represented her share in jointly owned properties. The Tribunal held that reassessment under section 147 is meant to bring to tax escaped income and cannot be converted into a proceeding for review or revision of concluded matters at the instance of the assessee. Relying on the settled principle that concluded issues cannot be reagitated in reassessment unless they relate to escaped income, the Tribunal found that the attempted reduction of the originally disclosed house property income was not permissible.

Conclusion: The assessee was not entitled to withdraw or reduce the income earlier offered in the original return through the reassessment return, and the addition sustained by the lower authorities was upheld.

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