Rajasthan HC says Reassessment Can Expand to New Escaped Income Under Amended Section 147

In Papu Ram v. Assistant Commissioner of Income Tax, the Rajasthan High Court upheld the Revenue’s power to expand pending reassessment proceedings to cover other escaped income discovered during those proceedings, including material found during a search. The Court held that the Explanation to amended Section 147 reflects the legislative intent to permit this expansion without a fresh Section 148A process for the subsequently discovered issue, and dismissed the writ petition challenging the reassessment.