Reassessment jurisdiction requires assessee-specific, year-specific information and cannot rest on unrelated employees' welfare contribution disallowances alone.
Reassessment jurisdiction under sections 147 and 148 requires recorded information that is specific to the assessee and the relevant assessment year. Explanation 2(i) does not permit reopening solely on generic group-search allegations without identified seized material, escaped income, or year-specific nexus. Approval under section 151 must reflect application of mind to those particulars. Further, other income may be assessed only after assessing or reassessing the income forming the recorded basis for reopening. A reassessment cannot therefore rest solely on a disallowance of delayed employees' welfare contributions unrelated to the recorded search-based allegations.
Issues: (i) Whether reassessment based on generic group-search reasons, without assessee-specific material for the relevant assessment year, and approval under section 151 was valid; (ii) Whether reassessment could be sustained solely on an unrelated disallowance of employees' welfare contributions when no addition was made on the matters forming the recorded reasons for reopening.
Issue (i): Whether reassessment based on generic group-search reasons, without assessee-specific material for the relevant assessment year, and approval under section 151 was valid.
Analysis: Explanation 2(i) to section 148 deems the Assessing Officer to possess information suggesting escapement of income following a search, but does not dispense with the requirement that such information relate to the particular assessee and the relevant assessment year. The recorded reasons identified only group-level allegations of unaccounted transactions, concealed income and bogus expenses, without identifying any seized document, digital material, escaped income, or assessment-year nexus concerning the assessee. Approval under section 151 on such generic reasons lacked the required application of mind.
Conclusion: The reassessment was invalid because the recorded reasons were vague and lacked assessee-specific particulars, and the approval under section 151 was vitiated by non-application of mind.
Issue (ii): Whether reassessment could be sustained solely on an unrelated disallowance of employees' welfare contributions when no addition was made on the matters forming the recorded reasons for reopening.
Analysis: Section 147 permits assessment of other income only after assessment or reassessment of the income forming the basis of reopening. Under the substituted reassessment framework, the jurisdictional foundation remains the identified information suggesting escapement of income. The reassessment made no addition regarding the search-related allegations recorded as its basis, while the sole disallowance concerning delayed employees' contributions was unrelated to those allegations or to any seized material.
Conclusion: The reassessment could not be sustained solely on the unrelated disallowance when no addition was made on the recorded grounds for reopening.
Final Conclusion: The reassessment lacked jurisdiction on two independent grounds, and the disallowance of employees' welfare contributions could not survive; its merits remained unadjudicated.
Ratio Decidendi: Reassessment jurisdiction must rest on assessee- and year-specific information forming the recorded basis of reopening, and cannot be sustained solely by an unrelated addition where no income is assessed on that recorded basis.