https://www.taxtmi.com/caselaws?id=798303 Reassessment initiated against a successor amalgamated entity was not invalid merely because notices and the assessment retained the predecessor's old PAN. Where the recorded reasons correctly identified the successor and its new PAN, and the successor participated without confusion or prejudice, the PAN mismatch was a rectifiable clerical defect under Section 292B. Conversely, reopening based on alleged escaped commission income could not support an unexplained unsecured-loan addition when no addition was made on the recorded reason. Explanation 3 to Section 147 permits assessment of other escaped income but not a new-issue addition after the original reopening ground yields none. en-us Tue, 01 Sep 2026 00:00:00 +0530 Fri, 04 Sep 2026 08:24:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798303 Reassessment initiated against a successor amalgamated entity was not invalid merely because notices and the assessment retained the predecessor's old PAN. Where the recorded reasons correctly identified the successor and its new PAN, and the successor participated without confusion or prejudice, the PAN mismatch was a rectifiable clerical defect under Section 292B. Conversely, reopening based on alleged escaped commission income could not support an unexplained unsecured-loan addition when no addition was made on the recorded reason. Explanation 3 to Section 147 permits assessment of other escaped income but not a new-issue addition after the original reopening ground yields none. Case-Laws Income Tax Tue, 01 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798303