Against order disposing objection and notice issued under section 148 of the Act, the assessee filed writ petition. Allowing the petition the Court held that the Assessing Officer had undertaken a detailed investigation in that regard including by retrieving information from the Delhi archives. The cost of assets and expenses in connection with transfer of the property and for perfecting title were also subject matter of a detailed scrutiny during the assessment proceedings. The assessee was specifically called upon to furnish the documentary evidence in support of cost of land, cost of construction and cost of improvement. The assessee had responded by providing details and the manner in which cost of acquisition had been computed. The Assessing Officer had examined the statements and elaborately dealt with the question whether indexation was available in respect of the amount paid by the assessee to his sisters. The assessee had made full disclosure regarding the facts and circumstances in which the amount was paid to his sisters and the Assessing Officer had considered the allowability of such deduction. Reassessment on the ground that the amount paid by the assessee to his sisters was not deductible from the sale consideration for the purpose of computing capital gains was on a change of opinion. It was impermissible for the Assessing Officer to seek reopening of the assessment to review his decision regarding the fair market value of the property or deduction on account of the amount paid by the assessee to his sisters or the expenses incurred by him. The notice issued under section 148 was set aside. (AY. 2016-17)