Reassessment notice was issued on ground that there were reasons to believe that assessee’s income chargeable to tax had escaped assessment  as regards claim of provision against unascertained liabilities, claim of excessive deduction under section 35(2AB), deduction claimed on account CSR expenses and donations and excess allowance of deduction. On writ the Court held that  questionnaire along with notices under section 142(1) were issued and further details were called for from time to time during course of assessment proceedings and assessee had furnished details called for from time to time.  In assessment order, Assessing Officer had also dealt with assessee’s claim for deduction under section 80IC and provision for expenses under section 37(1) which were disallowed.  Since four issued raised in reasons to believe were subject matter of consideration during assessment proceedings, reopening was on basis of change of opinion.Accordingly the  notice  and order disposing the objection is quashed. issued under section 148 was to be quashed and set aside.  (AY. 2016-17)