The Assessing Officer sought to reopen an assessment on the ground that due to delay in submission of TP study, the arm’s length price of the transaction could not be examined. Quashing the proceedings, the High Court held that Form 3CEB as well as the TP study were filed in time and that it was apparent from the record that the Assessing Officer had decided to neither refer the matter to the Transfer Pricing Officer nor did he himself examine the transactions. Having done so, he could not change his opinion and reopen a concluded assessment. (AY .2013-14)