Dismissing the petition the Court held that during the limited scrutiny assessment under section 143(3) the assessee did not make a full and true disclosure of all the material facts and, therefore, the Assessing Officer could not form any opinion regarding the fact that the companies through which the entire share business had been dealt with by the assessee, were bogus shell companies, through which the operators provided accommodation entries for routing the unaccounted money of the assessee-company. This fact came to light only after investigation conducted subsequent to the limited scrutiny assessment and it was only thereafter that the Assessing Officer had formed an opinion in this regard. Therefore, the case would not fall in the category of change of opinion.  The notice of reassessment was valid. (AY. 2015-16)