Dismissing the appeal of the Revenue the Tribunal held that the entire assessment order was silent with regard to the query relating to the unsecured loans and the computation of income was devoid of any addition which was basis for the Assessing Officer to believe that income had escaped assessment, that is, Rs. 88 lakhs. If the Assessing Officer had accepted the objections of the assessee, and had not assessed or reassessed the income, which was the basis of the notice, it would not be open to him to assess income under some other issue independently. The Assessing Officer’s reliance upon Explanation 3 to section 147 of the Act was misplaced. (AY.2007-08)