The Assessing Officer issued a notice, dated May 24, 2022, under section 148A(b) and the assessee filed a reply as required under section 148A(c) submitting that it did not sell any immovable property during the assessment year 2017-18 and therefore, no long-term capital gains arose also clarified that it had purchased an immovable property. On examination of the transactions and considering the assessee’s submissions an order dated July 30, 2022 was passed under section 148A(d) concluding that the reassessment proceedings under section 147 could be dropped. On the same date, the Revenue issued a corrigendum against the original order passed under section 148A(d) allowing the continuation of reassessment proceedings by issuing a notice under section 148 which had originally been dropped. On a writ petition  allowing the petition, that  the Court held that the proceedings were firstly closed by the Revenue by an order, dated July 30, 2022, under section 148A(d) upon being satisfied after examining the audited final accounts filed by the assessee indicating that there was no immovable property held by the petitioner as on April 1, 2016 relevant to the assessment year 2017-18 and therefore, there was no sale undertaken by it. On the same day itself, hours after terminating the proceedings, the Revenue had issued a corrigendum to initiate the reassessment proceedings under section 147, without any new material which warranted reopening the assessment. From the two notices it would crystallize that the corrigendum had been issued merely on the basis of a change of opinion as two different conclusions had been drawn on the basis of same material, i. e., audited final accounts of the assessee. The Assessing Officer had apparently reviewed his own decision, which was not permissible. Therefore, the notice issued under section 148 via corrigendum to the order, dated July 30, 2022, under section 148A(d) and the consequential reassessment proceedings under section 147 were unsustainable and hence quashed. (AY. 2017-18)