The assessee had deposited specified bank notes during the demonetisation period. In the scrutiny assessment completed under section 143(3) on December 31, 2019, the Assessing Officer had examined this issue in detail and accepted the return of income after verifying the records. Later, on the basis of audit objection, notice under section 148A(b) was issued on March 19, 2024. The Court held that the power to reopen assessment post April 1, 1989 is wider, but the words “reason to believe” cannot be interpreted so as to permit reopening merely on a change of opinion. Since the issue of demonetisation cash deposits had already been examined and accepted in scrutiny, the reassessment amounted to review of the same matter, which is impermissible. Accordingly, the notice and order disposing of the objection were quashed as invalid. (AY.  2017-18)