Assessee, a registered charitable Trust, filed its return of income and claimed an accumulation of Rs. 70 lakhs for being used for charitable and religious purposes in India over a period of five years under section 11(2) of the Act. In audit report and in return of income, inadvertently it was mentioned that such accumulation was against section 11(1)  which  was  explained during course of assessment proceedings which  was accepted. The AO issued notice for reassessment. On writ the Court held that  reassessment notice  due to change of opinion hence the notice was quashed. (AY.2016-17)