Dismissing the appeal the Court held that merely because the assessee did not raise any objection against the reassessment proceedings before the Assessing Officer, that did not mean that the question of validity of reassessment had attained finality and could not be challenged before the appellate forums. The quintessence of the matter was to examine whether or not the reassessment was valid and not whether or not any objection was taken by the assessee before the Assessing Officer. On facts the The Commissioner (Appeals) had recorded that the Assessing Officer in the original assessment proceedings and thoroughly examined the issue of date of commencement of the project. Thus, it was manifest that the reassessment came to be initiated by the Assessing Officer on the basis of no fresh material coming to his possession after the completion of the original assessment, which was, in fact, made only for the verification of claim of the deduction under the computer aided scrutiny selection. Rather it was a case of change of incumbent who reviewed the material existing on record and took a contrary view. Such change of opinion was strictly impermissible. There was no reason to disturb the finding recorded by the Commissioner (Appeals) that the reassessment proceedings were bad in law. (AY. 2009-10)