S.147: Reassessment-After the expiry of four years- Transfer pricing-Arms’ length price-Avoidance of tax-International transaction-Gurantee fees- Pending before Tribunal- Court held that the Assessing Officer was debarred from initiating reassessment proceedings on that very issue -Re assessment notice and order disposing the objection was quashed. [S.92C, 143(3), 148, Art. 226]