Allowing the petition the Court held that  the Principal Commissioner had dropped the revision proceedings under section 263 accepting the assessee’s reply and hence, it was evident that at the time of original scrutiny assessment under section 143(3) and the revision proceedings under section 263, the authorities were aware of the shares held by the assessee for a consideration which was considered to be less than the fair market value. The reasons for issuing notice under section 148A(b) were exactly similar to the reasons on which the Principal Commissioner had invoked section 263. Once the Principal Commissioner had decided in favour of the assessee after having considered its reply, the Assessing Officer had no authority to reopen the assessment under section 147. Reopening of assessment was on mere “change of opinion” and the reassessment proceedings were in the nature of review of the original assessment. Grant of approval by the Principal Chief Commissioner would not confer legitimacy to the initiation of the reassessment as the issue on which the reassessment was initiated, had already been considered in the original proceedings. The higher authority could not grant approval which was in violation of the settled principles on the basis of which reassessment action could be initiated. The initial notice under section 148A(b), the order passed under section 148A(d) and notice under section 148 and the consequential proceedings under section 147 were set aside.(AY. 2014-15)