Reopening of assessment must be confined to the income that...

Reopening of assessment must be confined to the income that formed the assessing officer's belief; other income noticed during reassessment may be assessed only if the originally alleged escaped income remains assessed as escaped. Applying the jurisdictional precedent, where the AO after issuing a notice accepts the returned income on the issue that prompted reopening, the AO cannot independently compute deemed income based on book profit or levy MAT in that reassessment without issuing a fresh notice. Consequently the MAT computation in the reassessment was quashed as beyond the scope of proceedings.

---