Allowing the petition, the Court held that the reassessment was initiated on ground that as per section 35ABB, assessee was eligible for deduction on license fee but it had capitalized said fee as intangible asset and claimed 25 per cent depreciation which had resulted in allowance of excess depreciation, since said issue was examined by Assessing Officer in assessment proceeding, and neither was there any new information received nor was a reference made to any new material on record, in absence of any tangible material, present case was nothing but a case of change of opinion and, thus, did not satisfy jurisdictional foundation of section 147. Reassessment notice and order disposing the objection was quashed. (AY. 2016-17)