Allowing the petition the Court held that the Assessing Officer had mechanically recorded that the return was processed only under section 143(1) which itself suggested that he had recorded reasons in a mechanical manner and with no application of mind. At the time when the assessment order under section 143(3) was passed, the then Assessing Officer was in possession of the details of the transactions done through the entity DC and these could not be made the subject matter again to assume jurisdiction under section 147 of the Act for reopening of the assessment, since it had already been concluded. Reopening of the assessment under section 147 on the basis of the same details was nothing but a change of opinion which was not permissible in the eyes of law. The notice issued under and the order rejecting the assessee’s objections were quashed and set aside.(AY. 2011-12)