https://www.taxtmi.com/caselaws?id=465378 Reopening under s.147/s.148 was tested against the requirement that the escaped income forming the recorded "reason to believe" must be assessed for the reassessment to survive. Relying on HC authority and the construction of s.147 read with Expln. 3, the Tribunal held that while other income found during reassessment may be taxed, it is permissible only if the item triggering reopening remains part of the reassessed income ("and also bring to tax"). Here, reopening was based on alleged under-disclosure in a property purchase, but the purchase was duly accounted and no addition was made on that ground. The reassessment was therefore invalid, the order under s.143(3) r.w.s. 147 was set aside, and the appeal was allowed. en-us Wed, 23 Apr 2025 00:00:00 +0530 Thu, 18 Dec 2025 22:30:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465378 Reopening under s.147/s.148 was tested against the requirement that the escaped income forming the recorded "reason to believe" must be assessed for the reassessment to survive. Relying on HC authority and the construction of s.147 read with Expln. 3, the Tribunal held that while other income found during reassessment may be taxed, it is permissible only if the item triggering reopening remains part of the reassessed income ("and also bring to tax"). Here, reopening was based on alleged under-disclosure in a property purchase, but the purchase was duly accounted and no addition was made on that ground. The reassessment was therefore invalid, the order under s.143(3) r.w.s. 147 was set aside, and the appeal was allowed. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465378