Jeet Singh v. ITO (2022) 98 ITR 331 (Delhi) (Trib)

S. 147 : Reassessment-Notice-Additions made on the ground different from reassessment grounds-Reassessment not sustainable. [S.148]

The Tribunal held that when the Assessing Officer had not made any addition on the issues for which the case of the assessee was reopened, he could not make any other addition without issuing fresh notice under section 148 after recording escapement of income and therefore, the entire reassessment proceedings were quashed.(AY. 2008-09)