Allowing the petition the Court held that though in the order of assessment, there was no specific discussion as regards this particular claim, it must be presumed that the claim was considered and only then allowed. Neither was there any new information received nor was a reference made to any new material on record. In the absence of any tangible material, it was nothing but a change of opinion and therefore, did not satisfy the jurisdictional condition under section 147. The notice and the consequent order disposing of the objections raised for the reopening of the assessment were quashed. (AY. 2016-17)