The assessee had claimed deduction of ₹6,54,75,440 twice, firstly by reducing the said amount from sales and thereafter again claiming it as a deduction under other allowable expenditure. The Assessing Officer reopened the assessment beyond four years on the ground that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. The assessee was unable to demonstrate either before the AO or the Writ Court that it was not a case of double deduction. The High Court held that the reasons recorded for reopening were relevant and based on tangible material indicating escapement of income due to double deduction. Since the assessee had made a wrong claim and had not made full and true disclosure during the original assessment, the conditions for reopening beyond four years were satisfied. The Court also noted that the assessee had already availed the statutory appellate remedy before the CIT(A) and, having failed in the writ petition, could not reagitate the same issues. The assessee was at liberty to contest the merits of reopening before the appellate authority. Accordingly, the writ appeal was dismissed and the order of the Single Judge was affirmed. (AY. 2014–15)