The Assessing Officer issued a reopening notice alleging that the entire amount of ₹98.04 lakhs received by the assessee through Client Code Modification (CCM) constituted undisclosed income. The assessee argued that the AO had incorrectly treated the gross amount as taxable, whereas only the net income from buy and sell transactions-₹77,280-was relevant for tax purposes. High Court agreed, noting that the AO had failed to apply his mind to the nature of contra entries and had erroneously added both buy and sell amounts to compute escapement of income. The Court emphasized that only the net gain could be taxed and, since ₹77,280 was below the basic exemption limit for the year, no income chargeable to tax had escaped assessment. SLP  dismissed on grounds delay not satisfactorily explained.  (AY. 2014-15)