Assessee-company sold shares of two companies to a company namely SCPL for consideration of Rs. 40 lakhs.  Assessment was completed under section 143(3) without making any addition in respect transaction of sale of shares .After four years, Assessing Officer issued reopening notice against assessee on ground that assessee was beneficiary of accommodation entries to tune of Rs. 40 lakhs, which was sum received from SCPL . On writ the Court held that  Assessing Officer already had information with respect to certain shares which were sold for consideration to SCPL. If Assessing Officer was not satisfied with explanation furnished by assessee, at that stage, he could have exercised powers to make addition but did not choose to do anything on such count . Accordingly the action of reopening was merely change of opinion on same set of facts, which was disclosed and considered by Assessing Officer during assessment . Reassessment notice and order disposing the objection is quashed . ( AY. 2012 -13)