The Tribunal held that as regards the addition of Rs. 2,25,41,809 there was no notice to the assessee and the assessee was only made to explain the expenditure of Rs. 4,07,99,236 on account of loss on sale of repossessed assets and excess deduction. With regard to additions made on account of interest on inter-corporate deposits, there was no actual show-cause notice. In the original assessment the question of claim of loss of Rs. 2,95,61,000 on sale of vehicles repossessed by the assessee-company from defaulter parties was considered as manifested by the letter of the assessee addressed to the Assessing Officer. On the one hand, the reasons cited in the notice under section 148 of the Act were erroneous with regard to calling for reassessment in regard to a factor which was already examined in the original assessment. On the other hand, in the assessment order, an addition was made in regard to a head for which actually there was no notice to show cause issued. Thus, the Assessing Officer was in error in invoking jurisdiction under section 147 of the Act. Since the jurisdictional grounds raised by the assessee had been allowed making the reassessment illegal, the other grounds raised did not require consideration. (AY.  2006-07)