Allowing the petition the Court held that  the assessee’s bank had clearly stated in the reply that there were two different entries captured in the statement of account and remittance sheet had two different types of rates, one was notional and the other one was actually realised and statement of account submitted to the assessee, it was duly recorded in the books of account reflecting the actual realised rate of foreign exchange. The bank had given explanation and clarification from the Forex Department to the effect that the bank after receiving the bill from the party or customer, the bill amount was firstly calculated on notional rate decided by the bank from time to time and finally at the time of realisation of the bill, it was calculated on actual settlement or exchange rate on that day. On application of the basic accounting principles, the assessee had produced all the material during the course of the regular assessment. When such record was already available with the Assessing Officer, which were produced by the assessee during the original assessment proceedings under section 143(3), he ought to have considered them and applied his mind with regard to the material made available by the survey action under section 133A which was conducted on the bank coupled with the explanation tendered by the bank. The notice issued under section 148 was on change of opinion on the part of the Assessing Officer on borrowed satisfaction without there being any fresh tangible material to prima facie conclude that income had escaped assessment and hence quashed and set aside.(AY. 2016-17, 2017-18)