During scrutiny assessment, Assessing Officer issued notice raising query with respect to 13 plots sold by assessee.  Pursuant to said query, assessee pointed out that copies of development agreements and financial statements reflecting income for said agreements were duly offered to tax. Considering said submissions assessment order was passed.  On writ against the reassessment proceedings, the Court held that  since specific query in respect of purchase and sale of properties was raised in assessment order, reopening undertaken beyond a period of four years was a change of opinion and same is  quashed.  (AY. 2015-16)