Dismissing the petition the Court held that prima facie the lack of full disclosure was present as the Dispute Resolution Panel had examined all three aspects, namely transfer pricing, railway siding charge (whether capital or revenue expenditure) and interest from debenture, tax impact thereof and after examining all three aspects had held in favour of the assessee only with regard to transfer pricing. This could not be completely ignored. In a scrutiny assessment even the details of the immovable property said to have been purchased by the assessee writ petitioner had not been given. The notice of reassessment after four years was valid. (AY. 2013-14)