Pursuant to survey AO issued notice u/s. 148 of the Act.  Tribunal  held that  perusal of figures in statement furnished in respect of income as reported in return furnished u/s 148 proved that there was huge difference. It was only after re-opening matter and verification of re-conciliation of royalty and FTS income as declared in return u/s 147 with TDS details of SIEL, AO recorded that Royalty/FTS income as offered to tax in such returns was acceptable. Merely because tax was deducted at source on such income it could not be said that there was no escapement of income. It was open under Explanation 3 to section 147 for AO to reassess income on any issue which newly came to his notice subsequent to issuance of notice u/s 148, it could not be said that mere wrong mentioning of provision of law relating to other issues in reasons recorded would vitiate proceedings. (AY. 2004-05 to 2014 -15)