The High Court in  4 ITR-OL 517 (Bom) in their pointer held that in this case the director’s report and which was before the AO as well has been referred to. In the director’s report, under the head “International operations”, all details as to how the acquisition was made and under what documents with all the salient features and the benefit occurring to the company have been pointed out. Reference was also made to note No. 10 in the notes forming part of the profit and loss account. It is in these circumstances that we are of the view that there is merit in submission that the reas- sessment is undertaken only on account of change of opinion.
It is always better to submit during assessment annual report , directors report , notes and any other statutory reports that highlight material transactions and agreements in the relevant year tocounter inquiry/ notice u/s 148A.