https://www.taxtmi.com/caselaws?id=376303 Reassessment under Sections 147 and 148 must be founded on the Assessing Officer's own lawful satisfaction within the statutory time limits, and an appellate direction cannot by itself confer jurisdiction to reopen an assessment. Where the reopening is beyond limitation and the mandatory approval under Section 151 is absent, the notices and resulting assessments are void. The text also states that an addition cannot be sustained on a ground different from the recorded reasons for reopening when no addition is made on the original basis. On these principles, the reassessment for the earlier years was quashed and the later-year addition was deleted. en-us Fri, 21 Dec 2018 00:00:00 +0530 Thu, 07 Mar 2019 06:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=376303 Reassessment under Sections 147 and 148 must be founded on the Assessing Officer's own lawful satisfaction within the statutory time limits, and an appellate direction cannot by itself confer jurisdiction to reopen an assessment. Where the reopening is beyond limitation and the mandatory approval under Section 151 is absent, the notices and resulting assessments are void. The text also states that an addition cannot be sustained on a ground different from the recorded reasons for reopening when no addition is made on the original basis. On these principles, the reassessment for the earlier years was quashed and the later-year addition was deleted. Case-Laws Income Tax Fri, 21 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=376303