Dismissing the petition the Court held that  the intricacies involved in the issues required an elaborate adjudication. The assessee was a large taxpayer unit and certain intricacies in deeper manner requires more adjudication with reference to the issues raised. It was for the assessee to participate in the reopening proceedings and avail of the opportunities to be provided for the purpose of completion of reopening proceedings. The Assessing Officer had established that he had reason to believe for reopening of assessment and there was no infirmity in the reopening of the assessment under section 147 / 148 of the Act. (AY. 2013-14)