Tribunal held  that no additions were made for the grounds taken by the Assessing Officer towards formation of belief and the addition was eventually made under the deeming fiction of section 2(22)(e). No relevant material was referred to by the Assessing Officer for applicability of section 2(22)(e) of the Act at the time of recording the reasons. The applicability of section 2(22)(e) was discovered at a subsequent stage in the course of assessment. Thus, it was not permissible for the Assessing Officer to supplement the reasons and make additions on the contours of section 2(22)(e) of the Act for which no reasons were recorded. The additions made by the Assessing Officer towards deemed income under section 2(22)(e) of the Act, being extraneous to the reasons recorded, had to be struck down on this score. Followed  CIT v. Mohmed Juned Dadani (2013) 355 ITR 172 (Guj)(HC) Ram Bai v. CIT (1999) 236 ITR 696 (SC)  Hindustan Lever Ltd. v. R. B. Wadkar, Asst. CIT  (No. 1) (2004) 268 ITR 332 (Bom)(HC) and East Coast Commercial Co. Ltd. v. ITO (1981) 128 ITR 326 (Cal) (HC). Tribunal held that the approval memo given by the Joint Commissioner noted the name of the assessee with many other assessees and granted a consolidated approval for action under section 147 of the Act stating “your proposal for reopening the above cases under section 147 of the Act is hereby approved”. Any reference to formation of “satisfaction” of the Joint Commissioner prior to approval, even in brief, was missing. Hence, in the absence of express satisfaction recorded by the Joint Commissioner while granting approval under section 151 of the Act, the consequential action of the Assessing Officer under section 147 could not be upheld. This apart, a consolidated approval memo of multiple assessees without recording satisfaction qua each individual case raised serious doubt on the plausibility of implicit satisfaction for each case as contemplated in section 151 of the Act. As regards the legal objection raised by the assessee on the validity of assumption of jurisdiction under section 147 read with section 151 of the Act and consequent additions carried out under section 2(22)(e) of the Act within the framework of the provisions of section 147 of the Act struck to the root of the matter and therefore, could be challenged before the Tribunal even if not raised or not argued before the lower authorities. Accordingly  the proceedings under section 147 / 148 of the Act were void ab initio and the additions made under section 2(22)(e) of the Act bad in law. (AY. 2013-14)