Where the reasons for reopening are non-existent or not sustained, there is no question of making any other additions as the reassessment itself is bad in law. (AY 2004-05)
Ratnagiri District Central Co-Operative Bank Ltd. v. DCIT (2019) 197 TTJ / 175 DTR 327 (Pune)(Trib.)
S. 147 : Reassessment–After the expiry of four years–No additions sustained on the reasons recorded–Reassessment is bad in law . [S. 148]