Allowing the petition the Court held that the reasons provided by the Department for the reopening of the assessment were based on the tax audit report and the information available in the books of account of the assessee. Reopening of assessment was sought to be made on exactly the same materials that were available with the Assessing Officer in the first instance during the original assessment and which had been disapproved by the Supreme Court. Therefore, there was a mere change of opinion on the same materials. The reassessment notice under section 148 and the consequential order rejecting the assessee’s objections were quashed. (AY. 2014-15)