Assessee and her spouse were joint owners of a flat which was sold and composite long-term capital loss was computed. Assessing Officer had accepted loss as booked by assessee. Reassessment proceeding is initiated on the ground that instead of a loss there was a capital gain. On writ the Court held that   since notice  was issued after expiry of four years from end of relevant assessment year and there was no failure on part of assessee to disclose truly and fully material facts and issue regarding capital loss on sale of said flat was subject of assessment proceedings, it was a clear case of change of opinion and reopening of assessment is  unjustified. (AY. 2015-16)