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Section 147 of the Income-tax Act, 1961 - Income escaping assessment - General - Whether when there exists material on record to arrive at a conclusion about escapement of certain income from assessment and in reassessment proceedings such income is not found to have escaped assessment, it is still open to Assessing Officer to complete reassessment proceedings on basis of certain other materials in respect of certain other income found to have escaped assessment - Held, yes CASES REFERRED TO CIT v. Ram Singh [IT Appeal No. 65 of 2006, dated 20-5-2008] [Para 3] and CIT v. Atlas Cycle Industries [1989] 180 ITR 319/ 46 Taxman 315 (Punj. & Har.) [Para 3]. ORDER 1. These five appeals arise out of the common judgment of the learned Tribunal dated 8-9-2005. The appeals relate to different assessment years, starting from 1994-95 to 1998-99. The appeals were admitted on different dates, by framing the common questions of law being:- "(i)Whether on the facts and circumstances of the case, the Tribunal was justified in adjudicating the validity of reasons accorded by the Assessing Officer at the time of assuming jurisdiction under section 147 with reference to the ultimate finding reached by the Assessing Officer notwithstanding holding that the information received from DDI constitutes valid material on the basis of which required satisfaction can be reached by the Assessing Officer for assuming jurisdiction under section 147? (ii)Whether on the facts and in the circumstances of the case, the learned Tribunal was justified in quashing the reassessment and the consequential additions made therein holding that the passing of order under section 143(3) read with section 147 assessing the other income based on assessee's alleged statement before the DDIT because it did not form part of reasons recorded under section 148?" 2. Though two separate questions have been framed, but in substance they comprehend the common question. The precise controversy is, that reasons were recorded for assuming certain income to have escaped assessment, however during reassessment proceedings, that income was not found to have escaped assessment, but then on the basis of certain other…

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