Scope of reassessment: AO may address newly noticed income but remains constrained by the recorded reasons for reopening.
Where the AO has recorded reasons to believe income escaped assessment, the AO may assess or reassess issues that come to notice during reassessment, but if no additions or modifications are ultimately made in respect of the issues that formed the basis for reopening, the AO cannot make additions or modifications relating solely to other matters that were part of the original assessment. Explanation 3 applies only after reassessment power is validly invoked and cannot be used to deviate from or supplant the recorded reasons.