Assessment Reopening Challenged: Insufficient Reasons by AO for Associating Assessee with Biomatrix u/s 147.

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....Reopening of assessment u/s 147 - reasons to believe - the reasons recorded by the AO do not lead to the conclusion that the assessee and Biomatrix were associated enterprises, and, therefore, it could not be said that any income, on account of ALP adjustment, had escaped assessment. - AT....