On appeal the Court held that, the reassessment proposed, within the six year period was perfectly in order, if the amounts in question had not already been disallowed in the original assessment order itself. The assessee had claimed the deduction in the assessment year 2005-06. According to S.10B(3) , the deduction claimed under S.10B had to be in respect of the amounts which were brought into the country, within six months from the close of the previous year. The previous year had ended on March 31, 2005 and the assessee ought to have brought the amounts into India prior to September 30, 2005, unless the period had been extended by the Reserve Bank of India as provided under Explanation to sub-section (3) of S. 10B . If such extension had not been granted, definitely there was a suppression in so far as the assessee having had filed return, presumably, only after the closure of the previous year, which was after the date prescribed in sub-section (3) of S. 10B for bringing the amounts into the country. In the reassessment proceedings, the specific contention raised by the assessee as to the deduction claimed, under S. 10B , having already been carried out was to be verified.( AY. 2005 -06)