Dismissing the writ petition, that the indisputable fact was that the assessment in the case of one of the assessees was completed even before the completion of the survey proceedings (though the assessment proceedings in the other two writ petitions were completed after the survey. The nature of the information shared by the assessee’s accounts officer, showed that the threshold bar for initiation of the reassessment proceedings was satisfied. At this stage, the Assessing Officer’s subjective prima facie opinion, though based on the records made available during the assessment proceedings, was because of further enquiry into the affairs of H, and this was not a case of change of opinion. The contention that the assessee’s only obligation in law once approval was granted under section 35(1)(ii) of the Act was to file a copy of the approval and the details of the donations made, and even if the approval was later withdrawn retrospectively because of certain allegations against the entity which was granted approval, the concluded assessment proceedings could not be reopened, this would have to be examined as part of the reassessment proceedings based on the further material that would be made available on record by the assessee and would not be a reason for interference at this stage. The notice of reassessment was valid.(AY. 2012-13, 2013-14, 2015-16)