On writ the Court held that  there was some basis for reopening the assessment. However, the assessee had placed additional documents on record. These documents indicated that the assessee transferred the shares to S on February 12, 2015. If the documents were found to be valid and genuine on verification, they indicated that the share transfer took place during the financial year 2014-2015 and not 2015-2016. This would have a material impact on the reassessment proceedings initiated by the Assessing Officer. Consequently, the assessee should be provided an opportunity to place these documents for consideration by the Assessing Officer before the Assessing Officer prepared the draft assessment order. In order to facilitate this process, the draft assessment was liable to be set aside.(AY. 2016-17)