Section 37 read with section 147 of the Income Tax Act, 1961 — Business Expenditure — Reassessment was unjustified as AO reopened assessment to disallow payment on account of technical knowhow fees made by assessee by holding it to be only adding as intangible asset falling within domain of section 32(1)(ii) and allowing only 25percent depreciation, since issue regarding payment of technical knowhow fee was markedly considered by Assessing authority and matter was also referred to TPO who considered said payment and had also assessed amount as TP adjustments on same which was included in assessed income separately by AO in assessment order under section 143(3) — Commissioner of the income tax vs. Hyundai Motor India Ltd [2019] 267 Taxman 200 (Madras)