The Assessing Officer issued reassessment notice on ground that entire expenditure claimed by assessee was CSR expenditure and disallowed it by placing reliance on Explanation 2 to section 37(1) of the Act. On writ allowing the petition the Court held that there was no failure on part of assessee to disclose fully and truly all relevant details regarding expenditures incurred by it, pursuant to which an assessment order under section 143(3) was passed.  There was no tangible material available on record to conclude that income had escaped assessment.  Reasons recorded by Assessing Officer indicated that he had relied upon facts and figures available from audited account.  Provision of Explanation 2 to section 37(1) inserted with effect from 1st April 2015 operates prospectively, from assessment year 2015-16  same was not in statute during year under consideration. Further, Explanation 1 would also not be applicable as CSR expenditure was incurred as required by section 135 of Companies Act, 2013 and its proposed disallowance would not constitute an offense. Accordingly the reassessment notice and order disposing the objection was  quashed and set aside.   (AY. 2013-14)