In the reasons for the proposed re -opening of assessment it was recorded that after the assessment order was passed the department received certain information from the Directorate of Income Tax , Intelligence  & Criminal Investigation Chennai from where it was fund that the acquisition of brands and the assessee has claimed incorrect depreciation  . On writ the Court held that  on consideration of facts the AO has conclusively taken one view and based on same material , it will not be open to reopen the assessment to take another view . The fact pertaining to the acquisition of Good will , Trade Mark , Patents and Brands were not only available before the Original assessment by the AO but were also analysed by the AO during the original assessment proceedings . The Court observed that it was true that there was no detailed reference to the query raised by the AO during the assessment proceedings and reply provided by the assessee along with documentary evidence . But , once the query raised was subject to the consideration of the AO , while completing the assessment , it is not necessary that the assessment order should contain reference and / or discussion to disclose his satisfaction in respect of each of query raised . If the AO has to record the consideration bestowed by him on all issues raised during the assessment proceedings  even where he is satisfied , then it would be impossible for the AO to complete all the assessments which are required to be scrutinized by him  under section 143(3) of the Act. Notice issued for reopening of assessment was quashed .   ( WP No. 3546 of 2019 dt. 4-1 -2022 )( AY. 2012 -13 )