Reopening assessments: reassessment may cover subsequently discovered income even if original reasons cease to survive.
Whether an assessing officer may assess income that comes to his notice during reassessment proceedings when the recorded reasons for reopening cease to survive is contested. Parliament's explanatory provision states the officer may assess any such subsequently discovered issue notwithstanding its omission from the originally recorded reasons, but high courts are split: some treat the provision conjunctively and limit reassessment when initial reasons fail, while others read the parts independently and permit assessment of subsequently discovered income if the notice itself is valid. (AI Summary)