Allowing the petition the court held that  the assessee had been categorising and claiming expenditure incurred on programmes/film rights as revenue for several years and this stand had not been found fault with by the Department. Such expenses were also reflected faithfully in its financials that had been circulated specifically in the course of the original assessment proceedings, notwithstanding that they had been filed along with the return of income. The statutory condition imposed for availment of the extended period of limitation had not been satisfied and the proceedings for reassessment for the assessment year 2011-12 were barred by limitation. As regards the assessment year 2013-14, the proceedings had been initiated within four years from the end of the relevant assessment year. The two questions proposed for reassessment, being amortisation of programme/movie cost and deduction of tax on foreign remittances, arose from a perusal of the financials themselves. The audited financials, including the profit and loss accounts and audit report, presented clearly all details in regard to these two issues. Admittedly, and even in terms of the reasons stated, there was no new material that had come to the notice of the authorities and the exercise was undertaken solely on the basis of the materials already supplied by the assessee and available on the records of the Department. Moreover, the proceedings for reassessment had been initiated on the basis of an objection raised by an audit party. Accordingly the notice was not valid.( AY.2011-12, 2013-14)