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Reassessment cannot be sustained for an unrelated income item where the income forming the recorded reasons is accepted and no addition is made on that basis. The notes explain that an Assessing Officer who initiated reassessment to examine share application money could not independently add an unsecured loan identified through separate information without issuing a fresh notice under section 148. Applying the principle in Jet Airways and a subsequent ITAT decision, the reassessment addition was treated as outside the permissible scope of reassessment. The assessee succeeded on this legal issue, and the merits of the unsecured-loan addition and other grounds were not examined.
Reassessment cannot be sustained for an unrelated income item where the income forming the recorded reasons is accepted and no addition is made on that basis. The notes explain that an Assessing Officer who initiated reassessment to examine share application money could not independently add an unsecured loan identified through separate information without issuing a fresh notice under section 148. Applying the principle in Jet Airways and a subsequent ITAT decision, the reassessment addition was treated as outside the permissible scope of reassessment. The assessee succeeded on this legal issue, and the merits of the unsecured-loan addition and other grounds were not examined.
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