The assessment was completed u/s 143(3) of the Act. Reassessment notice was issued on the ground that firstly, mark-to-market loss on restatement of outstanding forward contracts was a notional loss and not allowable as a deductible expenditure; secondly, assessee was not allowed to carry forward and set off losses of SEZ units against other taxable income; thirdly, cost of software licenses debited to profit and loss account as ‘other expenses’ ought to be treated as intangible assets eligible for depreciation at rate of 25 per cent and excess expenditure ought to be disallowed; fourthly, disallowance effected in terms of section 14A ought to be enhanced as average value of investment had been taken at a lower sum and; lastly, provision for customer rebate and billed receivables was to be added back to computation of income. On writ the Court held that   all issues which were sought to be dealt within impugned reopening proceedings, were noted at time of assessment and officer had also pointed queries to assessee and sought details that were furnished and it was only thereafter that an order of scrutiny was passed. Though there might be no specific mention of all issues in question in order of assessment, however, very fact that issues were raised at time of assessment and responses solicited that assessee had duly furnished, would make it clear that these issue had not escaped attention of Assessing Authority.   The assessee had made a full and true disclosure originally and there was also no material found by officer post original assessment.  Since reasons proceed wholly on basis of materials furnished by assessee originally reopening was unjustified. (AY. 2012-13)