Reopening an income-tax assessment on the same factual material...

Reopening an income-tax assessment on the same factual material already forming the subject of consideration before the appellate authority was impermissible where additions originated from digital data seized during a search and used under the separate statutory provision dealing with search-derived material. The reasoning rested on the bar against initiating reassessment proceedings based on identical seized material that was under appellate scrutiny, and consequently the reopening notice was quashed, preventing further reassessment on that same material.