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Validity of reopening of assessment u/s 147 - CIRP proceedings - The proceedings under the Insolvency and Bankruptcy Code, 2016 (IBC) cannot be pressed into service to dilute the rights of the Income Tax Department under the Income Tax Act, 1961 to re-open the assessment under Section 148 of the Income Tax Act, 1961. - Income Tax Department was not precluded from reopening the assessment completed under Section 143(3) of the Income Tax Act,1961. - HC