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TMI Blog2018 (6) TMI 1574X X X X Extracts X X X X X X X X Extracts X X X X ..... ut of the order passed by the Ld. CIT(A) on 11.12.2017 in relation to the assessment year 2002-03. 2. The only grievance raised through various grounds is against the confirmation of addition of Rs. 25,06,400/-. 3. Briefly stated the facts of the case are that some information was received by the Assessing Officer from Directorate of Investigation that the assessee had received accommodation ent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 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 Rs. 5,25,000/-. Section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... een the income escaping assessment forming reasons to believe for issuing notice u/s 148 and other income chargeable to tax which escaped assessment and comes to the notice of the AO in the course of the proceeding, amply shows that the existence of the former is a pre-condition for taxing the latter. To put it simply, if the grounds set out in the re-assessment notice are nonexistent, i.e., eithe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment 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 incomes chargeable to tax which escaped assessment and come to his notice subsequently in the course of proceedings u/s 147. The Hon'ble jurisdictional High Court in CIT vs. Chiel ..... X X X X Extracts X X X X X X X X Extracts X X X X
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