TMI Blog2018 (6) TMI 1574X X X X Extracts X X X X X X X X Extracts X X X X ..... uch grounds or the addition so made does not pass the scrutiny by the appellate forums, then, obviously, no further addition can be made for income which comes to the notice of the AO during the course of proceedings u/s 147. Without there being such a deterrent, the AO would acquire an unhindered power to initiate reassessment at the drop of a hat without any legally sustainable reasons and then make other additions resulting in multiplicity of proceedings, which the legislature has sought to curb. Any lawful jurisdiction to make addition on account of other incomes coming to the notice of the AO during the course of proceedings u/s 147 can be acquired only on the foundation of a validly acquired jurisdiction on legally sustainable ite ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... which reassessment proceedings were initiated. The Ld. CIT(A) got convinced with the assessee s explanation about the genuineness of transaction of ₹ 5,25,000/-. He, therefore, deleted such addition. The other addition of ₹ 25,06,400/- was sustained against which the assessee has come up in appeal before the Tribunal. 4. I have heard the rival submissions and perused the relevant material on record. It can be seen from the discussion made supra that the AO resorted to the re-assessment on account of one reason. The addition so consequently made stood deleted in the first appeal. No material has been brought on record to demonstrate that the Revenue has preferred any appeal against the impugned order deleting the addition of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g such a deterrent, the AO would acquire an unhindered power to initiate reassessment at the drop of a hat without any legally sustainable reasons and then make other additions resulting in multiplicity of proceedings, which the legislature has sought to curb. Any lawful jurisdiction to make addition on account of other incomes coming to the notice of the AO during the course of proceedings u/s 147 can be acquired only on the foundation of a validly acquired jurisdiction on legally sustainable items of income escaping assessment forming reasons for issuing notice u/s 148. In other words, if the AO fails to acquire a valid jurisdiction to make reassessment on the basis of his reasons, then, he is also debarred from making additions for other ..... X X X X Extracts X X X X X X X X Extracts X X X X
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