https://www.taxtmi.com/caselaws?id=801075 Section 147 permits assessment of income discovered during reassessment only after the Assessing Officer assesses or reassesses the income forming the recorded basis for reopening. The expression "and also" operates cumulatively, and Explanation 3 does not remove that substantive condition. Where no addition or adverse finding is made on the share-transfer issue recorded for reopening, an unrelated addition for unexplained cash credit cannot be sustained in that reassessment. A fresh notice under Section 148 is required to pursue the unrelated income; otherwise, the reassessment is without jurisdiction and void. en-us Tue, 29 Sep 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801075 Section 147 permits assessment of income discovered during reassessment only after the Assessing Officer assesses or reassesses the income forming the recorded basis for reopening. The expression "and also" operates cumulatively, and Explanation 3 does not remove that substantive condition. Where no addition or adverse finding is made on the share-transfer issue recorded for reopening, an unrelated addition for unexplained cash credit cannot be sustained in that reassessment. A fresh notice under Section 148 is required to pursue the unrelated income; otherwise, the reassessment is without jurisdiction and void. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801075