https://www.taxtmi.com/caselaws?id=794393 Reassessment under section 147 must remain linked to the recorded reason for reopening; if no addition is made on that issue, a disallowance on a different issue cannot survive. Here, reopening was based on alleged understatement of sale consideration for capital gains, but the Assessing Officer made no addition on that recorded ground and instead disallowed the section 54 deduction. The disallowance was therefore unsustainable and was deleted, with the challenge to the reassessment succeeding. en-us Tue, 16 Jun 2026 00:00:00 +0530 Sat, 04 Jul 2026 08:15:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794393 Reassessment under section 147 must remain linked to the recorded reason for reopening; if no addition is made on that issue, a disallowance on a different issue cannot survive. Here, reopening was based on alleged understatement of sale consideration for capital gains, but the Assessing Officer made no addition on that recorded ground and instead disallowed the section 54 deduction. The disallowance was therefore unsustainable and was deleted, with the challenge to the reassessment succeeding. Case-Laws Income Tax Tue, 16 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794393