Consistency between reassessment notice and recorded satisfaction bars additions founded on a different explanation for land investment.

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....Reassessment under sections 148A(b) and 148A(d) requires the reasons recorded for reopening to correspond with the information and grounds put to the assessee for explanation. Where a notice treated land as undisclosed and an unexplained investment, but the subsequent satisfaction accepted its disclosure and instead questioned the source of acquisition funds, the basis of reopening changed completely. Fresh or supplementary reasons cannot sustain reassessment without prior notice under section 148A(b). The Tribunal therefore quashed the reassessment, leaving the merits of the addition unadjudicated.....