It cannot be said that AO has not applied his mind when all material was placed by Assessee before him

In the impugned order dt. 13th Dec., 2007 reference has been made to the provisions of Expln. 1 to s. 147 which provides that the production before the AO of account books or other evidence from which material evidence could, with due diligence, have been discovered by the AO will not necessarily amount to disclosure within the meaning of the section. In our view, this is not a case which attracts Expln. 1 to s. 147. This was a case in which the AO raised specific queries on several occasions and all the queries were answered. It was also sought to be contended that since the AO had not expres...