Tribunal held thatno addition was made by the Assessing Officer in the reassessment proceedings for the reasons recorded in the notice issued under section 148 . If after issuance of notice under section 148 the Assessing Officer accepts the contentions of the assessee and holds that the income which he initially formed a reason to believe had escaped assessment, had as a matter of fact not escaped assessment, it was not open to him independently to assess some other income. The assessment order was illegal since the Assessing Officer had not made any addition on the “reasons to believe” recorded in the notice issued under section 148 and had himself so admitted because the early withdrawal of the amount deposited in the capital gains account before the expiry of the time period provided under section 54F had been offered to tax by the assessee and shown as income for the assessment year 2011-12. ( AY.2008-09)