Reopening of assessment should not be used where rectification power can correct apparent mistakes, to avoid undue prejudice.
Where an apparent mistake exists in an assessment order, the Assessing Officer must invoke rectification power rather than reopening; reopening requires contemporaneous recorded reasons, relevant material supporting a belief that income escaped assessment, and cannot be used to reargue conclusions from the same material. Parallel reopening while rectification is pending is invalid, and reopening for simple computational or apparent errors is disproportionate and prejudicial when rectification is an available efficacious remedy. (AI Summary)