Allowing the petition the Court held  the approval granted could not have been based on the reasons as recorded. Even on the merits, the notice had been issued after four years of the scrutiny assessment and all the three points in the reasons had already been considered during the assessment proceedings. Even if the assessment order were silent on one or two points, the Assessing Officer should still be considered to have applied his mind, once a query was raised and answers were provided. The notice of reassessment  and order disposing the objection is quashed. (AY.2006-07)