On writ High Court quashed the reassessment notice on the ground that the Assessing Officer could not have formed a prima facie belief that there was escapement of income in view of the material available on record during the original assessment proceedings  and the notice was  on a change of opinion on the part of the Assessing Officer on borrowed satisfaction without there being any fresh tangible material to prima facie material.  SLP of revenue  dismissed as the delay of 181 days in filing the special leave petition had not been satisfactorily explained  and also on merits. (AY. 2016-17, 2017-18)