On writ the Court held that the assessment was merely based on the basis of change of opinion which did not constitute justification  or reasons to believe that the income chargeable to tax has escaped assessment. There was a specific contention that he Assessing Officer had strongly objected to the audit query and had filed a detailed reply in support of his action of allowing the claim. There was no denial in the affidavit-in-reply and on the contrary it was simply stated that it was matter of record, factual and formal in nature, and therefore, no comments were offered. The notice issued under section 148 and the order rejecting the assessee’s objections were quashed and set aside. (AY. 2013-14)