https://www.taxtmi.com/caselaws?id=779669 Reassessment under sections 147 and 148 must stand or fall on the reasons recorded for reopening, and the Assessing Officer cannot substitute a different basis at the assessment stage. Here, the recorded reason referred to alleged receipt of an accommodation entry, but the addition was ultimately made on the footing that the assessee had provided accommodation entries and earned commission. Because the reassessment proceeded on a materially different foundation from the recorded reasons, the Tribunal held the jurisdiction to reopen was unsustainable. The reassessment was therefore treated as bad in law and without jurisdiction, and the Revenue's challenge to deletion of the addition failed. en-us Wed, 22 Jan 2025 00:00:00 +0530 Fri, 10 Oct 2025 08:44:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779669 Reassessment under sections 147 and 148 must stand or fall on the reasons recorded for reopening, and the Assessing Officer cannot substitute a different basis at the assessment stage. Here, the recorded reason referred to alleged receipt of an accommodation entry, but the addition was ultimately made on the footing that the assessee had provided accommodation entries and earned commission. Because the reassessment proceeded on a materially different foundation from the recorded reasons, the Tribunal held the jurisdiction to reopen was unsustainable. The reassessment was therefore treated as bad in law and without jurisdiction, and the Revenue's challenge to deletion of the addition failed. Case-Laws Income Tax Wed, 22 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779669