Held that even though the Assessing Officer did not discuss the issue of taxability of receipt he did make inquiry on it, sought clarifications from the assessee, applied his mind and got satisfied about its non-taxability on the basis of the view taken by him in the assessment order under section 143(3) for the immediately preceding assessment year, namely, 2010-11, when the order for the immediately preceding assessment year passed under section 143(3) treating the amount of headquarters fees as not chargeable to tax was available on record before the Assessing Officer, he was well justified in adopting such a possible view on the non-taxability of the amount for the year under consideration as well. Such an assessment order could not be construed as erroneous as well as prejudicial to the interests of the Revenue.  (AY. 2011-12)