Reassessment founded on additions and disallowances in later assessment years lacks a subsisting basis where appellate orders for those years delete or decide in the assessee's favour every issue relied upon for reopening. Although later assessment orders may initially constitute material for reopening, the reasons to believe that income escaped assessment cease once their foundation is removed. The reassessment notice and rejection of objections were quashed, while other challenges remained open and proceedings could revive if the Revenue succeeds in pending appeals on a foundational issue.
Reassessment founded on additions and disallowances in later assessment years lacks a subsisting basis where appellate orders for those years delete or decide in the assessee's favour every issue relied upon for reopening. Although later assessment orders may initially constitute material for reopening, the reasons to believe that income escaped assessment cease once their foundation is removed. The reassessment notice and rejection of objections were quashed, while other challenges remained open and proceedings could revive if the Revenue succeeds in pending appeals on a foundational issue.
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