Held that  even if there was no reply filed by assessee the onus is on Department to justify the reopening. If one considers the material relied upon by respondents to reopen, there are two buy and two sell. What has been brought has been sold or what has been sold only has been brought. It is well-settled that only the net income from the buy and sell transactions can be brought to tax in assessee’s hand and not the entire sum as done in this case. There is no attempt to even apply their mind as to how, when there are contra entries of buy and sell, both amounts could be added to say escapement of income. Therefore, in this case, considering the figures as given in the reasons for reopening, net income from the buy and sell transactions amounts to only Rs. 77,280 which can be brought to tax in assessee’s hand and not the entire amount of Rs. 98,04,340. Assessee has stated that this net income also is less than the maximum amount which is not chargeable to income-tax for the assessment year in question and accordingly no income chargeable to tax has escaped assessment in assessee’s hand. Reopening is not therefore sustainable. (AY. 2014-15)