Allowing the petition the Court held  that it was only upon consideration of complete disclosures made by the assessee, the original assessment order was passed for the assessment year 2015-2016. The Tribunal for the assessment year 2011-2012, in the assessee’s own case, had taken the view that there was no requirement to set off the losses incurred in one unit against the profits of the other unit following the decision of the Supreme Court. The Department had admitted that reassessment proceedings were initiated due to audit objection. No such reason was given to the assessee along with the notice seeking to reopen the assessment under section 147. The jurisdictional parameters for reopening the assessment beyond four years had not been satisfied. Reopening of the assessment was on mere change of opinion. Proceedings to reopen an assessment were not akin to review proceedings. The notice issued under section 148, the draft assessment order and the consequential proceedings were quashed. (AY.2015 16)