Court Rules Reopening of Assessment Unnecessary u/s 147 Due to Adequate Initial Explanation by Appellant.

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....Reopening of assessment u/s 147 - it is very clear in view of the detailed explanation filed by the appellant the AO had formed an opinion before passing the original assessment order and the appellant had discharged the evidences to the satisfaction of the assessing officer. Therefore in view of the above compliance the appellant was not in default within the proviso to section 147 with regard to R&D expenses. Therefore the second limb of the reasons recorded under section 147 for reopening fails the test of the said section. - AT....