Allowing the petition the Court held that All the details relating to the payment of royalty were supplied by the assessee commencing from the disclosures in the annexures to its return of income. Queries and responses specific to the issue were exchanged between the assessee on the one hand and the Transfer Pricing Officer and the Assessing Officer on the other. The reasons for reassessment were premised upon the classification of the royalty paid by the assessee being capital in nature, as against the claim of its being revenue in nature, by the assessee and nowhere contained an allegation of any failure by the assessee to make a disclosure in this regard. The order rejecting the objections raised by the assessee was quashed. (AY. 2013-14)