https://www.taxtmi.com/caselaws?id=793092 Reassessment cannot be sustained on a new disallowance when the recorded reason for reopening, here cash deposits, does not result in any addition and no fresh notice is issued under section 148. The Assessing Officer accepted the assessee's explanation on the original cash-deposit issue, but then made a disallowance of deduction under section 80P(2)(a)(i) on a different ground not covered by the reopening reasons. Applying the principle that reassessment must remain linked to the income for which notice was issued, the new issue could not be introduced without a fresh notice. The reassessment was therefore invalid and the disallowance was quashed. en-us Tue, 12 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793092 Reassessment cannot be sustained on a new disallowance when the recorded reason for reopening, here cash deposits, does not result in any addition and no fresh notice is issued under section 148. The Assessing Officer accepted the assessee's explanation on the original cash-deposit issue, but then made a disallowance of deduction under section 80P(2)(a)(i) on a different ground not covered by the reopening reasons. Applying the principle that reassessment must remain linked to the income for which notice was issued, the new issue could not be introduced without a fresh notice. The reassessment was therefore invalid and the disallowance was quashed. Case-Laws Income Tax Tue, 12 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793092