Held that the Forest Department of the Government of Andhra Pradesh had cancelled the assessee’s sale deed on November 20, 2008 on the ground that the land in question was Government reserve forest land. No other sale deed other than that had been executed at the assessee’s behest. The assessee could not have been held to have derived any taxable income once the sale deed itself stood annulled by the State Government. The Assessing Officer’s reason to believe that the assessee’s taxable income from sale of properties during financial year 2008-09 did not survive. Tribunal also held that the Department’s contention that the Assessing Officer could take up issues other than those specified in the reopening in terms of Explanation 3 to section 147 of the Income-tax Act, 1961, inserted with retrospective effect from April 1, 1989 was not tenable. The validity of reassessment proceedings is a sine qua non for any additions being made to the income of the assessee, during the course of the reassessment proceedings whether or not in respect of the reasons recorded for reopening the assessment. (AY.  2009-10)