The Assessing Officer initiated section 148 / 147 proceedings against the assessee on the ground that the assessee’s taxable income liable to be assessed had “escaped assessment”. He made addition of Rs.6,56,89,219 in the hands of the assessee. The assessee invoking rule 27 of the Income-tax (Appellate Tribunal) Rules, 1963 challenged the validity of the reopening on the ground that not only the Assessing Officer had not recorded the appropriate reasons for reopening based on independent opinion but also the notice u/s. 148 had not been served on him. Tribunal held that the assessee’s arguments could not be allowed to be raised under rule 27 once he had not pressed them in the lower appellate proceedings. Relied: Commissioner of Customs v.. Dilip Kumar & Co. [2018 6 GSTR-OL 46 (SC). (AY. 2008-09)