Allowing the petition the Court held that the  Assessing Officer had already examined and accepted assessee’s claim for deduction under section 35(2AB) for scientific research expenditure in original assessment under section 143(3), reopening assessment under section 147 by issuing notice under section 148 and order under section 148A(d) to revisit same issue on the same material amounted to a mere change of opinion, which was impermissible and without jurisdiction. Notice issued under section 148 and order under section 148A(d) were quashed.  (AY. 2013-14)