Reopening of assessment u/s 147 - Once a query has been raised...

Reopening of assessment u/s 147 - Once a query has been raised by Assessing Officer through the assessment proceeding and the assessee has responded to that query, it would necessarily follow that Assessing Officer has accepted petitioner's submissions so as not to deal with that issue in the assessment year. Even if, the assessment order passed under Section 143(3) of the Act does not reflect any consideration of the issue, it must follow that no opinion was formed by Assessing Officer in the regular assessment proceedings - it would not be open to reopen the assessment based on the very same material with a view to take another view - HC