Allowing the petition the Court held that the notice of reassessment was based on the ground that the allowance for bad debt was erroneous. During the original assessment proceedings, the Assessing Officer had considered the claim of the assessee in detail. The assessee had submitted all the required details called for by the Assessing Officer in respect of the claim of bad debts written off including the bad debts written off pertaining to export receivables. The Assessing Officer had formed an opinion that the bad debts from export receivables could be written off during the pendency of the application for approval from the Reserve Bank of India and he could not have formed a different opinion that income had escaped assessment because the assessee did not have permission from the Reserve Bank of India to write off the bad debts from the export receivables. The notice was not valid. (AY.2013-14)