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Section 148A reassessment procedure requires the Assessing Officer to identify the income alleged to have escaped assessment in the notice, consider the taxpayer's response, pass a reasoned order, and obtain prescribed approval. A reassessment addition for alleged loan-repayment cash deposits is unsustainable where those deposits were not identified in the section 148A proceedings or approved as escaped income. Where the originally proposed cash deposits were dropped after accepting the taxpayer's explanation, distinct deposits cannot subsequently be introduced through reassessment. The loan-repayment addition was therefore deleted, without adjudicating the remaining merits grounds.
Section 148A reassessment procedure requires the Assessing Officer to identify the income alleged to have escaped assessment in the notice, consider the taxpayer's response, pass a reasoned order, and obtain prescribed approval. A reassessment addition for alleged loan-repayment cash deposits is unsustainable where those deposits were not identified in the section 148A proceedings or approved as escaped income. Where the originally proposed cash deposits were dropped after accepting the taxpayer's explanation, distinct deposits cannot subsequently be introduced through reassessment. The loan-repayment addition was therefore deleted, without adjudicating the remaining merits grounds.
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