The assessee’s case was selected for scrutiny and it received notice under section 143(2). During relevant year, the assessee, along with other co-owners, entered into a Development Agreement with SA for developing land in Chikhloli, Ambernath. In the assessment proceedings under section 143(3), the assessee submitted a copy of the Development Agreement to the Assessing Officer. The Assessing Officer questioned whether the Development Agreement should be treated as the ‘transfer of the land,’ potentially resulting in capital gains. The assessee responded, explaining that the Development Agreement did not constitute a transfer of the land, citing relevant legal provisions. The Assesssing Officer accepted this explanation, and the assessment order under section 143(3) was issued, without making any capital gains addition. However, other additions were made to the petitioner’s total income. After four  years, the assessee received a notice under section 148, indicating that the assessing authority believed the assessee’s income for the assessment year 2013-14 had escaped assessment under section 147. The assessee also received a notice under section 142(1) and was provided with the recorded reasons for reopening the assessment. The assessee raised detailed objections in response to these notices, which came to be disposed of by order dated 14-2-2022. On writ petition, the assessee challenged this order and the notice issued under section 148. Allowing the petition the Court held that once a query is raised during the assessment proceedings and the assessee has replied to it, it follows that the query raised was the subject of consideration of the Assessing Officer while computing the assessment. It is not necessary that an assessment order should contain reference and/or discussion to disclose its satisfaction in respect of the query raised. This would also indicate that there was no failure to disclose any material fact.  Notice and order disposing the objection is quashed and set aside. (AY. 2013-14)