https://www.taxtmi.com/caselaws?id=799414 Reassessment jurisdiction requires the income identified in the recorded reasons for reopening to be assessed; Explanation 3 to Section 147 does not permit unrelated additions where that foundational escapement is not assessed. Such additions are without jurisdiction and must be deleted. Separately, an assessment issued in the name of an amalgamating company after it has ceased to exist is invalid, even if the successor participates. Notice of amalgamation prevents jurisdiction from being sustained through participation or estoppel. Reassessment and consequential additions founded on these defects are legally unsustainable. en-us Thu, 05 Mar 2026 00:00:00 +0530 Tue, 22 Sep 2026 08:17:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799414 Reassessment jurisdiction requires the income identified in the recorded reasons for reopening to be assessed; Explanation 3 to Section 147 does not permit unrelated additions where that foundational escapement is not assessed. Such additions are without jurisdiction and must be deleted. Separately, an assessment issued in the name of an amalgamating company after it has ceased to exist is invalid, even if the successor participates. Notice of amalgamation prevents jurisdiction from being sustained through participation or estoppel. Reassessment and consequential additions founded on these defects are legally unsustainable. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799414