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Raj Hans Towers Pvt. Ltd. vs Commissioner Of Income Tax-V on 24 July, 2015

22. Applying the proposition laid down in these case laws to the facts of this case, we uphold the contentions of the assessee that the AO cannot consider additions other than those material in the reasons for reopening in the absence of fresh tangible material. In case fresh tangible material comes to the possession of the AO on any other issue, then the proper course of action would be, to record fresh reasons and issue a fresh notice u/s 148 . Thus the additions made by travelling beyond the reason for re-opening, without tangible material , is bad in law..
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