Assessee-company engaged in business of manufacturing lubricating oils, filed its return of income for AY 2017-18. It disallowed a portion of CSR amount as per Explanation 2 to section 37(1) and additionally, it claimed a deduction under section 80G for donations to approved trusts/institutions-Return was selected for scrutiny, and after providing necessary details, an assessment order was passed, allowing claimed deductions.  Subsequently, AO issued a notice for reopening assessment, alleging income escapement. On writ allowing the petition the Court held that   from records that before finalizing original assessment order, AO raised queries to which assessee responded adequately, clarifying that deductions were only claimed under section 80G, supported by donation receipts and AO had examined all these aspects while passing original assessment order.  Further, documents on record also indicated that Audit Wing of Department raised certain objections to original assessment order including issue of deduction under Section 80G and AO justified original assessment order to audit party without accepting any adjustment to same.   In view of above, it could be said that assessment was reopened on basis of a change of opinion and it lacked tangible information on basis of which AO allegedly formed requisite belief. Accordingly the reassessment notice and order disposing the objection is quashed. (AY. 2017-18)