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A reassessment based on alleged escapement of interest income could not be sustained when no addition was ultimately made on that recorded ground and the Assessing Officer instead disallowed loan processing fees, an item outside the reopening reasons. Applying Jet Airways, the Tribunal held that once the recorded basis for reopening failed, the officer could not independently assess a different issue without a fresh reopening notice. The addition was therefore deleted for want of jurisdictional foundation, and the assessee's appeal was allowed.
A reassessment based on alleged escapement of interest income could not be sustained when no addition was ultimately made on that recorded ground and the Assessing Officer instead disallowed loan processing fees, an item outside the reopening reasons. Applying Jet Airways, the Tribunal held that once the recorded basis for reopening failed, the officer could not independently assess a different issue without a fresh reopening notice. The addition was therefore deleted for want of jurisdictional foundation, and the assessee's appeal was allowed.
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