“11. Having heard learned counsels, we are of the view that there is no merit in the present petition. So far as the petitioner’s challenge to the reopening of the proceedings is concerned, this Court has already rejected the same by observing that it shall be open to the petitioner to raise all its pleas before the Assessing Officer. The Assessing Officer is now carrying on further investigation, for which purpose notices under Section 142(1) have been issued to the petitioner. It is for the petitioner to comply with the said investigation. The Assessing Officer has already given an assurance to the petitioner that the petitioner would be confronted with whatever material is sought to be relied upon during the course of re-assessment, and that the petitioner would be granted ample opportunity in the matter. We have no reason to assume, at this stage, that the Assessing Officer would not undertake the re-assessment proceedings in accordance with law. In any event, if there is any infraction of law by the Assessing Officer in the matter of carrying out the re-assessment proceedings, and the petitioner is aggrieved by the re-assessment order that the Assessing Officer may pass, it shall be open to the petitioner to raise all its pleas in appeal, firstly, before the CIT (Appeals), and thereafter, before the ITAT, if necessary.
