Reopening of assessment u/s 147 - Failure to rely upon the...

Reopening of assessment u/s 147 - Failure to rely upon the decision of HC / SC at objection stage - We fail to understand why these decisions could not have been taken at this stage itself so that the AO, having regard to the law laid down by the courts and on the submissions made by petitioner, could have discharged the notice u/s 148 of the Act. There is no reason to postpone it to the assessment proceedings stage. - HC