Allowing the petition the Court held that, even in a case where the return is accepted u/s 143(1) without scrutiny, the fundamental requirement of income chargeable to tax having escaped assessment must be satisfied. Mere non-disclosure of receipt would not automatically imply escapement of income chargeable to tax from assessment. There has to be something beyond an unintentional oversight or error on the part of the assessee in not disclosing such receipt in the return of income. In other words, even after non-disclosure, if the documents on record conclusively establish that the receipt did not give rise to any taxable income, it would not be open for the AO to reopen the assessment referring only to the non disclosure of the receipt in the return of income. The attempt of further verification would amount to rowing inquiry. (Distinguished,  ACIT v Rajesh Jhaveri Stock Brokers (P) Ltd ( 2007) 291 ITR 500 (SC) , Raymond Woollen Mills Ltd v .ITO (1999) 236 ITR 34 ( SC) followed Prashant S. Joshi v ITO ( 2010) 324 ITR 154 ( Bom) (HC), Inductotherm (India) ( P) Ltd v M.Gopaln Dy.CIT ( 2013) 356 ITR 481 ( Guj) (HC)     (AY. 2011-12) (WP No. 1230 OF 2019, dt. 25.06.2019)