Allowing the petition the Court held that  once a query is raised during the assessment proceedings and the assessee has replied to it, it follows that the query raised was a subject of consideration of the AO while completing the assessment. It is not necessary that an assessment order should contain reference and/or discussion to disclose its satisfaction in respect of the query raised. The only requirement is that the AO ought to have considered, the objection now raised in the grounds for issuing notice under S. 148, during the original assessment proceedings. In the case at hand, the AO having raised a query and the assessee having replied to it, it follows that the query raised was subject of consideration of the AO while passing the assessment order dt. 21st Dec., 2011. The reopening of assessment by the notice is merely on the basis of change of opinion of the AO from that held earlier during the course of assessment proceedings and this change of opinion does not constitute justification and/or reasons to believe that income chargeable to tax has escaped assessment. Followed Aroni Commercials Ltd. v. Dy. CIT & Anr. (2014) 267 CTR  228/ 101 DTR  244 (Bom) (HC)  (AY. 2009-10)