Reassessment additions based solely on material gathered after...

Reassessment additions based solely on material gathered after reopening cannot survive where no addition or modification is made on the issue that formed the basis for reopening. Although the Explanation to section 147 permits assessment of subsequently noticed income after a valid reopening, the Tribunal applied the principle that this power depends on making an addition on the foundational reopening issue. The condition applies equally to reassessment following search where section 148A procedure is dispensed with. As the Revenue did not establish any addition based on material available at initiation, all additions arising from subsequent enquiries and verification were deleted. Both appeals were allowed, with remaining grounds left open.