Assessee issued compulsory convertible debentures (CCDs) to its subsidiaries. Same was converted as optionally convertible debentures (OCDs). Subsequently, OCDs were redeemed and repaid along with premium on such OCDs to holding company.Assessee claimed deduction  towards premium paid. Assessing Officer allowed  claim.  After four years, Assessing Officer sought to reopen assessment on ground that entire premium amount was paid from securities premium account and not routed through profit and loss account and, thus, claim of entire amount should have been denied. On writ the Court held that reasons recorded by Assessing Officer nowhere stated that there was failure on part of assessee to disclose fully and truly all material facts necessary for assessment. The Assessing Officer had not disclosed which material facts, according to him, were not fully and truly disclosed by assessee for relevant assessment year.  Accordingly the notice and order disposing the objection was quashed. (AY. 2014-15)