Allowing the petition the Court held that ; the Assessing Officer had raised written queries during the original assessment and answers were given by the assessee to such questions. This included the applicability of the amended S. 2(15). The Assessing Officer in the order of assessment did not, with the aid of such provisions, hold that the activities of the trust are not for charitable purpose. He, thus, accepted the assessee’s stand in this regard. Any attempt now to re-examine this issue would be considered as change of opinion and clearly impermissible even if it was within the period of four years. The notice of reassessment was not valid.( AY. 2009-10)