Held that the assessee-firm, engaged in business of transmission towers for electric lines, claimed deduction for sub-contracting expenses and AO disallowed said expenses on ground that sub-contractors failed to provide evidence of work so done for assessee, since assessee could not carry out its contract work without engaging sub-contractors, only 10 per cent of alleged bogus sub-contracting expenses were to be disallowed. Reassessment is affirmed on the ground that the Assessing Officer is not required to establish escapement of income while recording reasons for reopening, notice issued under section 147 is valid. (AY. 2009-10 to 2012-12, 2016-17)