Allowing the petitions the Court held that there had been full disclosure by the assessee in the original scrutiny assessment in relation to the issues mentioned in the reasons recorded for reassessment and the Department had not discharged the statutory burden as stipulated in the proviso to section 147. The appendices to the return of income stated the particulars of the expenditure incurred under section 43B also referring to the rates and taxes of land tax, leave encashment, gratuity and others specifically referring to the amount transferred on demerger of the assessee which amount was alleged to have escaped assessment. The original order of assessment had been passed after accepting the submissions of the assessee. The reassessment proceedings were barred by limitation and the consequent orders were quashed. (AY.2012-13)