Assessing Officer Cannot Reopen Assessment u/s 147 if Taxpayer's Response is Unchallenged During Proceedings.

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....Reopening of assessment u/s 147 - where queries have been raised during the assessment proceedings and the assessee has responded to the same, then the non-discussion of the same or non-rejection of the response of the assessee, would necessarily mean that the AO has formed an opinion accepting the view of the Assessee - thus an opinion is formed during the regular Assessment proceedings, bars the AO to reopen the same....