Assessee is engaged in business of power generation. It filed its return of income which was accepted. Thereafter, Assessing Officer issued a reopening notice against assessee on ground that it had made investments from a common pool of funds and incurred common administrative and other expenditure, debiting it to Profit & Loss account thereby attracting provisions of section 14A and, thus, taxable income by virtue of incorrect claim of expenses had escaped assessment.  Queries raised by Assessing Officer in course of original assessment proceedings followed by replies given by assessee clearly showed that entire material was before Assessing Officer and applying his mind to said material, Assessing Officer had passed assessment order and statement of accounts regarding details of expenses and investment relating to earning of exempt income was accepted by Assessing Officer. On writ the Court held that there was no tangible material available with Assessing Officer to justify reopening of assessment. Accordingly thee  reopening of assessmenr was on basis of mere change of opinion, which is was impermissible in law.  (AY. 2016-17)