Dismissing the appeal, that nowhere in the record was it mentioned that the assessment had been reopened on the basis of an audit objection. If there was application of mind, it should be apparent from the material placed before the Tribunal. The details of purchases were available before the Assessing Officer at the time of the original assessment proceedings under section 143(3) of the Act and no new material had come to the knowledge of the Assessing Officer to take reassessment proceedings. It was merely a change of opinion and the Commissioner (Appeals) had considered the issue in the right perspective. The tax effect less than monetary limits  appeal of revenue is dismissed. CBDT Circular No. 17 Of 2019 Dated 8-8-2019
 [2019 416 ITR  (St.) 1. (AY. 2009-10)