Reassessment Grounds Dropped: No Further Additions Allowed Under Income Tax Act Sections 148A(b) and 148A(d.

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....Once the principal grounds on which reassessment was proposed are dropped, no further additions can be made even by taking recourse to Explanation 3. There is an indelible connection between Section 148A(b) and Section 148A(d) of the Act, which is not impacted by Explanation 3. The validity of initiation of reassessment must be independently evaluated and cannot be confused with the power ultimately available to the Assessing Officer once an assessment has been validly reopened. Explanation 3 comes into play only after it is found that the power to reassess has been validly invoked. It cannot be read as enabling the Assessing Officer to deviate from the original reasons for initiating action u/s 147/148, nor can it empower the officer to im.........