Assessee claimed carry forward of loss after setting off of brought forward losses which included losses pertaining to amalgamated company.  Assessing Officer allowed claim holding that as per section 72A(2) losses on amalgamation get fresh life for further 8 years form date of amalgamation.  Thereafter the  Assessing Officer reopened assessment on ground that amalgamated company will be entitled for claim for only unexpired period and not full 8 years afresh thus, assessee was not entitled for set-off of losses as it had exceeded period of carry forward of 8 years as prescribed in section 72(3) of the Act. On writ the Court held that since Assessing Officer in original assessment order considered all submissions and accepted loss to be carried forward and there was no failure to disclose any material fact, reopening was mere change of opinion and notice was  quashed.  (AY. 2014-15)