High Court Affirms No Grounds for Reopening Assessment u/s 148, Clarified by Circular No.717 on Section 33AC.

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....Reopening of assessment u/s 147 - No doubt this matter has also been set to rest by Circular No.717 issued by the Central Board of Direct Taxes wherein the Board explained the provisions of the amendment made to Section 33AC of the Act. It is clearly stated therein that the deduction prior to the amendment was available to the extent of the total income provided the amount was credited to reserve account and was utilised for the purchase of a new ship within the specified period. - no ground for initiating proceedings under Section 148 - HC....