https://www.taxtmi.com/caselaws?id=785562 Validity of reassessment under reopening provisions was examined in relation to an ad hoc 10% disallowance of expenses. The tribunal found that additions outside the subject matter of recorded reasons are permissible under the explanation only if the addition forming the subject matter of reopening is also made; absent such primary addition the reopening is vitiated and reassessment is void ab initio, requiring fresh notice. The AOs reliance on audited books for gross receipts but simultaneous ad hoc disallowance of expenses without rejecting books under applicable accounting provisions was held unjustified, so the disallowance was deleted and the appeal allowed. en-us Wed, 21 Jan 2026 00:00:00 +0530 Tue, 27 Jan 2026 07:36:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785562 Validity of reassessment under reopening provisions was examined in relation to an ad hoc 10% disallowance of expenses. The tribunal found that additions outside the subject matter of recorded reasons are permissible under the explanation only if the addition forming the subject matter of reopening is also made; absent such primary addition the reopening is vitiated and reassessment is void ab initio, requiring fresh notice. The AOs reliance on audited books for gross receipts but simultaneous ad hoc disallowance of expenses without rejecting books under applicable accounting provisions was held unjustified, so the disallowance was deleted and the appeal allowed. Case-Laws Income Tax Wed, 21 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785562