Allowing the petition the Court held that initially the contention of the assessee that such transfer of shares was a gift without consideration was accepted, subsequently the view was revised to treat the transfer of shares not as a gift and to tax the transaction on the market value of the shares. This was nothing but a change of opinion. It was quite apparent that the assessee had placed before the Assessing Officer during the assessment proceedings all the primary facts from which he made the inference. Now it was not open to the Assessing Officer to take a second view on the same set of facts treating the earlier view as erroneous. The notice of reassessment after four years was not valid. (AY. 2012-13)