S. 147 : Reassessment-Change of opinion – Notice based on assessment order of subsequent assessment year-Non-deduction of tax at source on payment made to non-resident, short and long term gains on share transactions- Provision for warranty – Deduction u/s 35(2AB )-No independent formation of opinion by Assessing Officer based on new material-Reassessment notice quashed and set aside. [S. 35(2AB), 148, Art. 226]