https://www.taxtmi.com/caselaws?id=468818 Section 147 does not permit reassessment additions on independent issues where the income forming the recorded basis for reopening is not assessed or reassessed; Explanation 3 does not authorise a roving inquiry without a fresh notice under Section 148. Accordingly, additions for irretrievable loss and ADR proceeds, unrelated to the fixed-deposit reasons for reopening, could not be sustained. Deletion of the suspense-account opening-balance addition required reconsideration because the alleged criminal-court order and forensic report relied on in appellate relief were unavailable on record. The matter was remanded for fresh adjudication after a remand report and hearing both sides. en-us Tue, 11 Feb 2025 00:00:00 +0530 Wed, 05 Aug 2026 11:21:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468818 Section 147 does not permit reassessment additions on independent issues where the income forming the recorded basis for reopening is not assessed or reassessed; Explanation 3 does not authorise a roving inquiry without a fresh notice under Section 148. Accordingly, additions for irretrievable loss and ADR proceeds, unrelated to the fixed-deposit reasons for reopening, could not be sustained. Deletion of the suspense-account opening-balance addition required reconsideration because the alleged criminal-court order and forensic report relied on in appellate relief were unavailable on record. The matter was remanded for fresh adjudication after a remand report and hearing both sides. Case-Laws Income Tax Tue, 11 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468818