Allowing the petition the Court held that a bare perusal of the reasons recorded for the notice under section 148, revealed that the findings recorded by the Assessing Officer with regard to non-production of the necessary documents in support of the claim were without any basis and reflected total non-application of mind to the record. The records indicated that the details with regard to deduction under section 54B were called for and the assessee had complied with furnishing the registered sale deed and agreement of purchase along with bank particulars. Deduction had been allowed to the extent of Rs.1,85,00,000/-. The attempt on the part of the Assessing Officer to reopen the assessment was nothing but a change of opinion. The notice was not valid. (AY. 2012-13)