The ssessee claimed deduction of depreciation on account of amortization of brand value  which was disclosed in notes to balance sheet and profit and loss account .Specific query was raised in the course of assessment proceedings as regards allowability of depreciation . After considering the reply the assessment was completed u/s143( 3) of the Act . Reassessment notice was issued on ground that there was no provision for granting deduction for amortization which was not charged in profit and loss account on notional basis; therefore, notional amount of depreciation was to be added back and since same was not done hence  income chargeable to tax had escaped assessment . On  writ the High Court held that  reason in support of reassessment notice was very issue in respect of which Assessing Officer had raised query during assessment proceedings and assessee responded to same justifying its stand  hence the reassessment was held to be not valid .On appeal by the revenue  dismissing the appeal of the revenue the Court held that , the reasons in support of the  notice is the very issue in respect of which the AO had raised a query during the assessment proceedings and the Petitioner had responded justifying its stand. The non-rejection of the explanation in the Assessment Order amounts to the AO accepting the view of the assessee, thus taking a view/forming an opinion. In these circumstances, the reasons in support of the notice proceed on a mere change of opinion and would be completely without jurisdiction . Order of High Court is affirmed .   (AY .2014 -15)  SLP No.7367/2020 dt .1-06 -2020