Reopening of assessment u/s 147 - where queries have been raised...

Reopening of assessment u/s 147 - where queries have been raised during the assessment proceedings and the assessee has responded to the same, then the non-discussion of the same or non-rejection of the response of the assessee, would necessarily mean that the AO has formed an opinion accepting the view of the Assessee - thus an opinion is formed during the regular Assessment proceedings, bars the AO to reopen the same