Dismissing the petition the Court held that the three lines omitted did not cause any prejudice to the interest of the assessee and the subject was categorically dealt with by the assessing authority throughout the proceedings and the assessee also had knowledge of these facts and circumstances and raised objections.  The mere information provided by way of the audit objection could not be a ground to quash the entire initiation of proceedings. Section 115WG provides wider scope for reassessment of fringe benefits chargeable to tax which escaped assessment. The scope provided for reopening of assessment of any fringe benefits escaping assessment cannot be narrowed down by the courts.The contention that it was a change of opinion was not tenable. The reasons were disclosed to the assessee. The assessee had responded to the reasons and certain typographical error would not constitute a ground for quashing the entire initiation of proceedings under section 115WG. The reason for reopening as contemplated would not be construed as a change of opinion.  and further the assessee has to submit all the details for the purpose of completing the reassessment proceedings. That the continuation of the proceedings based on the reopening of the assessment initiated by the erstwhile officer by invoking section 115WG could not be raised as a valid ground unless any mala fides are established against such officer. The assessee had to participate in the reopening proceedings by availing of the opportunities to be provided for the purpose of completion of proceedings. The disputed facts raised by the assessee could not be adjudicated by the writ court under article 226 of the Constitution of India. Such an adjudication has to be undertaken through original records and evidence made available.(AY.2009-10).