Allowing the petition the Court held that,a report of the Revenue audit party is merely information and opinion- It is not new or fresh or tangible material-If the reassessment notice is solely based on an audit opinion, it means it is issued on change of opinion which is not permissible .In the present case, the reassessment notice is solely based on an audit opinion. Having regard to the fact that the assessee’s challenge to the previous year’s re-assessment orders was successful – in FIS Global Business Solutions India Pvt. Ltd. v. ACIT 2018 (408) ITR 75 (Del), the reassessment proceedings are unsustainable.( W.P.(C) 12277/2018, C.M. APPL.47539/2018. Dt. 16.11.2018) (AY. 2011-12)