Allowing the petition the court held that  the  assessee had addressed letter dated October 8, 2014 to the officer in the course of assessment proceedings pointing out in clear terms that certain shares were sold.  The Department already had with it the information on that count. If the officer was not satisfied with the explanation furnished by the assessee, at that stage, he could have exercised powers to make addition but he did not choose to do anything on such count. Therefore, the action of the Assessing Officer was in the nature of change of opinion only. The notice of reassessment was not valid. (AY.2012-13)