Section 147 allows reopening of assessments in exceptional cases...

Section 147 allows reopening of assessments in exceptional cases where the Assessing Officer has reason to believe income has escaped assessment. Concluded assessments should not be interfered with lightly. If the reopening ground cannot be sustained, there is little rationale for expanding reassessment proceedings. A strict interpretation of Section 147 is warranted given the nature of unsettling concluded assessments. Courts have held reassessment is confined to issues forming the reasons for reopening. Explanation 3 to Section 147 clarifies the AO can assess other issues noticed subsequently but does not override Section 147's plain language. The AO cannot assess other incomes where no addition is made on the reopening reasons. No substantial question of law arises.