After conclusion of proceedings u/s 147 AO cannot take aid of Exp. 3 to Section 147 to make any addition

M/s JDC Traders Pvt. Ltd. Vs DCIT (ITAT Delhi)

A careful reading of Section 147 clearly shows that it empowers the learned AO to assess or re-assess the income in respect of any issue which had escaped the assessment irrespective of the fact that whether such aspect was adverted to in respect of the reasons recorded u/s 147 of the Act. Had the learned AO assessed to re-assessed the issue relating to the closing stock in the proceedings u/s 147, the assessee could not have agitated anything against the same stating that it is

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