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    <title>2020 (9) TMI 401 - ITAT MUMBAI</title>
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    <description>Reassessment initiated to examine alleged client code modification could not support independent additions on other issues after no addition was made on the recorded reason for reopening. Once the Assessing Officer accepts that the income alleged to have escaped assessment did not escape assessment, other issues noticed during reassessment cannot be examined for addition without a fresh notice under section 148. Consequently, revisional jurisdiction under section 263 could not direct examination of matters outside the permissible scope of reassessment, and the revisional order was unsustainable.</description>
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      <description>Reassessment initiated to examine alleged client code modification could not support independent additions on other issues after no addition was made on the recorded reason for reopening. Once the Assessing Officer accepts that the income alleged to have escaped assessment did not escape assessment, other issues noticed during reassessment cannot be examined for addition without a fresh notice under section 148. Consequently, revisional jurisdiction under section 263 could not direct examination of matters outside the permissible scope of reassessment, and the revisional order was unsustainable.</description>
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