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Whether the reopening of the assessment for the assessment year 2009-10, which was originally completed u/s 143(3) by making addition towards freezer deposit received between AY 2009-10, was valid to consider the same addition in respect of freezer deposits received by the appellant from inception up to assessment year 2006-07.

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Sec. 147 & 148 of Income Tax Act, 1961—Reassessment— Section 147 confers the power to reassess and not the power to review, the provision was incorporated in the scheme of" the Act so as to empower the AO to reassess any income on a ground which was not brought on record during the original proceedings and escaped his knowledge; and the fact would have material bearing on the outcome of the relevant assessment order - ASSTT. CIT V/s JOJO FROZEN FOODS P. LTD. - [2020] 81 ITR (TRIB) 090 (ITAT-COCHIN)

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