Assessing Officer issued a notice under section 148 on the ground that   there was no disclosure of long-term capital gains (LTCG) on sale of shares and that assessee would have paid brokerage/commission, therefore, income chargeable to tax had escaped assessment within meaning of section 147. On  writ the Court held that the  assessee had declared LTCG on shares of SAL and cash income in declaration under Income Declaration Scheme, 2016 and a certificate under section 183 of the Finance Act, 2016 was also issued to assessee. It was also  found that assessee had disclosed LTCG on sale of shares, purchase of equity shares of SAL, sale of those shares and gain in computation of income filed by assessee.  In response to notice issued under section 142(1), assessee gave entire details relating to transactions in shares of SAL and even in assessment order, long-term capital loss, short-term capital loss, etc. were discussed. It was also recorded in assessment order that capital gain was nil. Court held that   reopening was merely on basis of change of opinion of Assessing Officer and this change of opinion did not constitute justification and/or reason to believe that income chargeable to tax had escaped assessment  accordingly the notice and order disposing the objection is quashed.  (AY. 2014-15)