Reassessment was initiated in case of assessee-company and reasons for reopening of assessment were that depreciation on property was wrongly allowed; writing off an amount as bad debts in support of two companies where arbitration award had been given in favour of assessee was not justified, etc.   As regards said issues, query was raised by Assessing Officer in notice under section 142(1) and explanation had been given by assessee and thus, said issues were subject matter of consideration by Assessing Officer during original assessment proceeding  . On writ the Court held that  reopening of assessment was on basis of change of opinion and there was no reason for Assessing Officer to have a reasonable belief that income chargeable to tax had escaped assessment .  ( AY. 2003 -04 )