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TMI Blog2025 (3) TMI 1220X X X X Extracts X X X X X X X X Extracts X X X X ..... it entries in the bank account was furnished with supporting documents in view of the Judgement in the case of N. Govindaraju Vs. ITO (2015) 60 taxman.com 333/233 Taxman 376/377 ITR 243 wherein the Hon'ble Karnataka High Court held as under: "If notice under section 148(2) of the Act is found to be valid, then addition can be made on all grounds or issues which may come to notice of Assessing Officer subsequently during course of proceedings under section 147 of the Act even though reason for notice for 'such income which may have escaped assessment may not survive." 3. None appeared on behalf of the assessee nor any adjournment was sought. The ld. DR was heard at length. Case records carefully perused. With the assistance of the l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e reproduce as under for ready reference: "6. In the order u/s 143(3) 25.02.2014, the AO has admitted that Rs. 7,74,13,335 (Rs.6,19,31,108 according to the appellant) was received by the appellant as enhanced compensation and interest thereon on account of compulsory acquisition of property. The appellant made various investment out of this compensation which was credited in the Indusind Bank. These investments became the subject of reassessment proceedings. It is seen that the AO has not made any addition on account of any of the grounds for re-opening mentioned in Para 1 of the re- assessment order, accepting the submissions of the appellant filed during scrutiny proceedings. Instead, the AO made an addition of Rs. 1,72,49,370 being cre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITR 136 (Del) has held as follows: 25. The position in law which emerges from the aforesaid discussion is that while it is true that the AO would have to establish that reassessment is warranted on account of information in its possession which appears to indicate that income chargeable to tax had escaped assessment, once the assessment itself is reopened it would not be confined to those subjects only. This would, however, be subject only to one additional rider and that being if, in the course of reassessment, the AO ultimately comes to conclude that no additions or modifications are warranted under those heads, it would not be entitled to make any additions in respect of other items forming part of the original return. Following the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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