Reopening of Assessment Invalid: AO Failed to Identify Error in Explanation Regarding Non-application of Explanation to Section 73.

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....Reopening of assessment - the reasons recorded for re-opening shows that the AO did not find any error in the explanation of the assessee for non-application of Explanation to Sec. 73, but still invoked the provisions of Explanation to Sec 73 - re-opening in this case was not valid - AT....