https://www.taxtmi.com/caselaws?id=345103 Reopening under Section 147 must rest on a valid jurisdictional basis, and Explanation 3 does not enlarge the Assessing Officer's power to sustain reassessment on issues unrelated to the recorded reasons. Where no addition is made on the grounds stated in the reassessment notice, additions on other issues cannot independently keep the reassessment alive. In cases where notice is issued beyond four years, the requirement that the assessee failed to disclose fully and truly all material facts remains material, and unrelated additions cannot be used to bypass that statutory threshold. The reassessment was therefore not sustainable on the unrelated additions, and the issue was decided in favour of the assessee. en-us Wed, 05 Jul 2017 00:00:00 +0530 Thu, 10 Aug 2017 17:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345103 Reopening under Section 147 must rest on a valid jurisdictional basis, and Explanation 3 does not enlarge the Assessing Officer's power to sustain reassessment on issues unrelated to the recorded reasons. Where no addition is made on the grounds stated in the reassessment notice, additions on other issues cannot independently keep the reassessment alive. In cases where notice is issued beyond four years, the requirement that the assessee failed to disclose fully and truly all material facts remains material, and unrelated additions cannot be used to bypass that statutory threshold. The reassessment was therefore not sustainable on the unrelated additions, and the issue was decided in favour of the assessee. Case-Laws Income Tax Wed, 05 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345103