An order passed without discussion is liable for reopening

In respect of AY 2000-01, the assessee filed a ROI. In the accompanying balance sheet it was disclosed that prior period expenditure of Rs. 5,41,850 was debited to the P&L A/c and that interest of Rs. 8,34,720 receivable from a particular party had not been accounted for as income. The AO passed an order u/s 143(3) in which he did not make any addition on account of the aforesaid two items. Subsequently (within four years), he issued a notice u/s 148 in which he took the view that income had escaped assessment as the prior period expenditure was not allowable as a deduction and the interes...