Reopening of assessment u/s 147 - The tribunal has not...

Reopening of assessment u/s 147 - The tribunal has not considered the provisions of Explanation 2(b) to Section 153 of the Act, by which the Assessing Authority is empowered to include any income excluded from total income of a person and is treated to be income of another person, then such an assessment of the income on such other person shall be deemed to be made in consequence of or to give effect to any finding or direction contained in the said order. - Order of ITAT quashed - Decided in favor of revenue - HC