Allowing the petition the Court held that the reopening of assessment under section 147 of the Income-tax Act, 1961 in respect of the sale and purchase of property by the assessee was merely on a change of opinion. The Assessing Officer had relied upon the same information available from the assessment records and there was no new tangible material available with him to conclude that income had escaped assessment. The notice issued under section 148 and the order rejecting the assessee’s objections were quashed and set aside.( AY. 2015-16)