During scrutiny, Assessing Officer referred matter to TPO with respect to international transactions under section 92CA(1) and report was submitted determining ALP of these transactions.  On receipt of said report Assessing Officer issued a draft assessment order under section 144C.  However, Assessing Officer instead of passing final assessment order, issued a notice for reopening assessment under section 148. The assessee challenged the said notice by filing writ petition. Dismissing the petition the Court held that   there is no embargo under section 147, to issue notice under section 148, where assessment order has not been passed after starting scrutiny proceedings; and section 144C(4) only states that Assessing Officer has to pass an assessment order in accordance with provisions of Act and it nowhere states that reopening notice can be issued only after passing an assessment order-Held, yes-Whether thus, Assessing Officer is empowered to invoke section 147, if he has reason to believe that income chargeable to tax escaped assessment, even when no assessment orders are passed under sub-section (4) to section 144C. Accordingly the  reassessment proceeding initiated by Assessing Officer was held to be valid.  (AY. 2013-14)