High Court held that the entire transaction had been considered by the Assessing Officer and had culminated in the order under section 143(3) of the Act. As apparent from the reasons there were no new tangible material in the hands of the Assessing Officer. Once the assessment was concluded, it was deemed to have been concluded with application of mind by the Assessing Officer from all perspectives legal and factual. The reopening of the assessment based on a different method of computation or application of the section was nothing else but a change of opinion, which was impermissible in law. The reassessment notice and order disposing the objection was quashed. SLP of Revenue is dismissed.  AY. 2015-16