Allowing the petition the Court held that a specific query during the assessment proceedings was raised calling upon the assessee to provide a statement of capital gains and exemptions claimed along with evidence supporting the claim of exemption by a notice. The assessee provided all the details including a copy of the sale agreement. Subsequently, the assessee provided further details. Thereafter, the Assessing Officer issued a fresh notice under section 142(1) of the Income-tax Act, 1961 seeking further details on the immovable properties owned by the assessee. These details were also provided. In the assessment order, accepting the assessee’s explanations and return of income, it was mentioned specifically that benefit of deductions and exemption under section 54 of the Act was one of the reasons for scrutiny under computer assisted scrutiny selection and the assessee was issued notices and the assessee also provided all details online. Therefore, all the material relied upon by the new Assessing Officer proposing the reopening were available with the Assessing Officer when the assessment order dated December 15, 2018 was passed. Exemption had been granted. Reassessment notice was quashed. (AY.2016-17)