Tribunal held that the AO had come to the conclusion that there was escapement of income on the ground that falsification of books of account and also manipulation of accounts for the last several years as well as the statement given by the chairman and material evidence, which were necessary to be considered, were not at all considered by the AO  while passing the order under S.143(3) of the Act. The AO after  recording detailed reasons, had reopened the assessment and, therefore, the question of change of opinion did not arise because the AO  had  not expressed any opinion. Accordingly the reassessment is held to be valid.  On facts the CIT(A)  had   given the directions to the AO with regard to the addition of Rs. 20 crores on account of unexplained loans and advances and with regard to segregation of interest income and assessing it as income from other sources and treating the income from trading in shares as speculation income. (AY. 2005-06)