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Ground of appeal by Revenue is that on the facts and in the circumstances of thecase, the Ld. CIT(A) has erred in holding that in the proceeding u/s 148, no addition can be made on the other issues unless those other issues are connected to the issue on which reopening has been done.

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Sec. 147 of Income Tax Act, 1961—Reassessment— The jurisdictional fact which is sine qua non to assume jurisdiction is found to be lacking/absent and, therefore, the very invocation of jurisdiction to reopen itself is not existing and, therefore, when the foundation on which reopening was initiated is non-existing then the AO's assumption of jurisdiction is without jurisdiction and so all subsequent action is a nullity in the eyes of law - The condition precedent to reopen i.e. reason to believe escapement of income, which can be discerned from reading of the reasons recorded by the AO that too on a stand alone basis, the AO cannot proceed to make any other additions without making any additions on the facts specifically stated in the reasons recorded for which he decided to reopen. - ASSTT. CIT V/s HARSH VARDHAN NEOTIA - [2020] 28 ITCD Online 039 (ITAT-KOLKATA)