Held, that in the original assessment for the assessment year 2015-2016, notice had been issued calling upon the assessee to tender specific details relating to the issue of bad debt and non-performing assets in view of section 36(1) (vii) and section (viia) of the Income-tax Act, 1961. In response to the notice, a detailed reply was forwarded by the assessee on October 16, 2017 and thereafter, after having been satisfied, the Assessing Officer had not made any addition on this issue and passed an assessment order. The Assessing Officer had not thought it fit to make any addition with regard to the claim of Rs. 24.63 crores, and as such, when the material was very much available and accepted by the Assessing Officer while passing the assessment order, now to reopen that issue again was based upon a change of opinion. Hence, the notice dated March 26, 2021 and the order dated November 9, 2021 were liable to be quashed. (AY.2015-16)