Allowing the petition the Court held that undisputedly, the assessee had disclosed the transaction of having received a sum of Rs. 40.51 crores from Morarji Textiles Ltd. under a deed evidencing transfer of leasehold rights in the land. Not only in the return, but during the assessment also, the assessee had made such disclosures. This transaction was also examined by the Assessing Officer during assessment. In the reasons recorded itself, the Assessing Officer had referred to this transaction as emerging from the assessment records. Thus, in clear terms, the assessee had offered such receipt to tax. In the notice for reassessment the Assessing Officer held that the leasehold rights belonged to Morarji Textiles Ltd   itself and therefore, Morarji Textiles Ltd. was wrong in claiming that it had purchased such rights from the assessee. He recorded the satisfaction that the income of the assessee to the tune of Rs.40.51 crores chargeable to tax had escaped assessment. The entire issue had been examined by the Assessing Officer during the original scrutiny assessment. No material outside of the assessment records was shown to have been brought to the notice of the Assessing Officer. He only referred to the order of the assessment passed by the Assessing Officer of Morarji Textiles Ltd  such assessment was based on the documents which were already part of the assessment in the case of the assessee. The notice of reassessment was not valid. ( Distinguished  Kalyani Maviji and Co v. CIT (1976) 102 ITR 287 (SC), and  Phool Chand Bajrang Lal v. ITO (1993) 203 ITR 456 (SC)(AY. 2013-14)