The Assessee challenged notices issued under section 147 read with section 148 for reassessment of A.Y. 1989-99 to 2001-02, contending that the Assessing Officer was wrongly relying upon the order passed by the Transfer Pricing Officer (TPO) for A.Y. 2002-03, which related to a subsequent year and could not be relied upon for reopening assessments for prior years. It was also contended that the assessee was not in existence in the present form during those years. Dismissing the writ petitions and deciding in favour of the Revenue, the Court held that section 147 is not in any manner controlled by section 92 nor is there any limit to consideration of any material having nexus with the opinion on the issue of escapement of assessment of income. The order of the TPO can be taken into account for reassessment of a period prior to the amendment of section 92. Interference with a notice for reassessment is called for only where extraneous or absurd reasons are made the basis for the opinion proposing to reassess. In the present case the Assessing Officer had duly recorded reasons and material relied upon, which could not be declared wholly irrelevant or extraneous. No final order had been passed and the assessee would get full opportunity at the stage of framing assessment. The writ petitions deserved to be dismissed. (AY 1999-2000)