Dismissing the appeal of the revenue the Court held that in the assessment order the AO had clearly recorded the presence of the authorised representative of the assessee and that the case was discussed. Apart from that, the Assessing Officer was fully aware that the assessee-company was registered under section 25 of the Companies Act, 1956, and this was noted in the assessment order. There was absolutely no other material available with the assessee except the records which formed part of the assessment file. Therefore, the reopening was a clear case of change of opinion. The reassessment proceedings were not valid. (AY. 1998-99, 1999-2000, 2002-03)