Assessment which was completed u/s 143(1) was reopened u/s 148 and disallowed the travelling expenses Subsequently the AO issued the notice u/s 154 /155 of the Act and made addition in respect of difference of closing stock . Order of the AO is affirmed by CIT (A). On appeal the Tribunal held that  the AO cannot, after conclusion of proceedings u/s 147, take aid of Explanation 3 to S. 147 to make any addition u/s 154. If the Dept’s argument is accepted that u/s 154 the AO is empowered to deal with escapement of income even after the S. 147 assessment is completed, it would empower the AO to go on making one addition after the other by taking shelter of Explanation 3 to S. 147 endlessly. Such a course is not permissible. ( ITA No.5886/Del/2015,dt. 11.10.2019)(AY. 2007-08)