Dismissing the petition  Court held   that the debit and credit entries were the primary basis for proceeding with reassessment. During the course of the hearing, the assessee had undisputedly conceded that the transactions had been carried out between the parties mentioned. The assessee had not been able to allude to any enquiry either expressly or indirectly conducted by the Assessing Officer in the earlier assessment proceedings qua the issue under consideration, which could suggest that the present proceedings were merely based upon a change of opinion. Thus, the Assessing Officer could not be said to have traversed beyond its mandate to assume jurisdiction under section 147 of the Act.(AY. 2011-12)