The High Court allowed the assessee’s writ petition against the notice issued under section 148 of the Income-tax Act, 1961 and the order rejecting its objections to the notice, and quashed the notice and the order, holding that the reasons recorded for the notice did not indicate any failure on the part of the assessee, that the entire basis for reopening was a change of opinion of the Assessing Officer, that all the facts regarding the loss on cancellation of forward contracts, which the Assessing Officer should have disallowed as speculation loss, were available before the Assessing Officer, that nothing new had happened between the date of order of assessment and the date of formation of opinion by the Assessing Officer, and that when the primary facts necessary for assessment were fully and truly disclosed, the Assessing Officer was not entitled on a change of opinion to commence proceedings for reassessment.  SLP of revenue  was dismissed.  (AY. 2012-13)