https://www.taxtmi.com/caselaws?id=793494 In reassessment proceedings, an addition cannot be sustained on a ground not covered by the recorded reasons for reopening. Here, the notice under section 148 was based on alleged escapement of interest income from inter-corporate deposits, but no addition was made on that basis; the only sustained disallowance related to loan processing fees. As the recorded reasons did not include that issue and no fresh valid notice or recorded satisfaction supported it, the reassessment could not extend to an entirely different item. The addition was deleted and the reassessment was held unsustainable on that basis. en-us Mon, 15 Jun 2026 00:00:00 +0530 Wed, 17 Jun 2026 07:46:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793494 In reassessment proceedings, an addition cannot be sustained on a ground not covered by the recorded reasons for reopening. Here, the notice under section 148 was based on alleged escapement of interest income from inter-corporate deposits, but no addition was made on that basis; the only sustained disallowance related to loan processing fees. As the recorded reasons did not include that issue and no fresh valid notice or recorded satisfaction supported it, the reassessment could not extend to an entirely different item. The addition was deleted and the reassessment was held unsustainable on that basis. Case-Laws Income Tax Mon, 15 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793494