Court Quashes Reopening of Assessment u/s 147; AO's Claims of Delay Unsupported by Evidence.

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....Reopening of assessment u/s 147 - it appears that the AO has recorded to the effect that he could not refer the matter to the Transfer Pricing Officer nor could he examine the issue because of delayed submission of the revised reports - observations recorded by the AO are factually incorrect and contrary to the material evidence on record - while framing the assessment order, it would not reflect that due to non-submission of revised Accountant’s report or Form No.3CEB, AO could not determine the Arm’s Length Price or refer the issue to the Transfer Pricing Officer. - The notice is not sustainable, quashed - HC....