Allowing the appeal of the assessee the Tribunal held that where no addition was made on account of the income which have alleged to have escaped assessment , the Assessing Officer cannot make any addition on any different ground which did not form part of the reasons recorded . Relied on CIT v. Mohmed Juned Dadani ( 2014) 355 ITR 172 ( Guj) (HC) ( ITA No. 2414/ Ahd/ 2018 dt 20 -11-2020 ) (AY. 2013 -14)
Shri Tyrone Patrick Lemos v .ITO ( 2021) The Chamber’s Journal – March -P. 184 ( Ahd) (Trib)
S. 147 : Reassessment – No addition was made on reasons recorded – Additions made on any other income which does not form part of reasons recorded cannot be sustained [S.2(22)(e ), 148 ]