Court Invalidates Assessment: AO's Additions Beyond Original Reasons Violate Section 147, Assessment Must Be Quashed.

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....Reopening of assessment u/s 147 - No addition being loan given forming the main `reason for escapement of income’ u/s 147 of the Act has been made by the AO and instead, the additions have been made on new different grounds, it can be very fairly said that reasons recorded did not exist and hence the assessment framed u/s 147 read with section 143(3) of the Act deserves to be quashed. A.O. had no jurisdiction to travel beyond the reasons for reopening the assessment. - AT....