Nothing can be added or subtracted to reasons recorded for reassessment 

State Bank of India Vs DCIT (ITAT Mumbai) On perusal of the reasons recorded by AO in the instant case reveals that there was no new tangible material to reopen the assessment for AY. 2008-09 which has already undergone scrutiny assessment u/s 143(3) of the Act dated 28.12.2010. Therefore, first proviso to Section 147 of the Act would come into play, and therefore the additional condition precedent that while recording the reasons recorded for reopening of the assessment has to not only state his reasons to believe escapement of income, he has to also additionally record and specify what was t...