Dismissing the petition the Court held that the fact that the Assessing Officer had made a wrong reference as to the issue being pending before the High Court instead of before the Tribunal did not invalidate the foundation of the reasons recorded by him. It was obviously and apparently an inadvertent error in referring to the forum before which such issue was pending. Where the original assessment was not made after scrutiny, the Assessing Officer could not be stated to have formed any opinion and therefore, the concept of change of opinion did not apply. The reopening of the assessment was permissible.( AY. 2010-11)