Dismissing the petition the Court held that the materials on record which were made available to the Assessing Officer were in the form of a survey report after the conclusion of the scrutiny assessments for both the assessment years 2011-12 and 2012-13 and the relevant records were shared with the Assessing Officer only on March 19, 2018. Given the time constraint after analyzing the report of the survey including the statement recorded during the survey, the Assessing Officer was of the opinion that the issue of profitability required re-examination not because of a second opinion or review but because of the survey conducted subsequently. The materials on record showed that the sales declared were suspicious.  Reassessment proceedings are held to be valid. (AY. 2011-12 2012-13)