The assessee had sold the agriculture land during the relevant year and claimed the deduction u/s 54B and 54F against the capital gain earned on transfer of such agriculture land.  The case of the assessee was selected for scrutiny, the assessee submitted the series of evidences in support of the deductions claimed under both the sections and considering the submissions/explanations from the assessee in response to the specific SCN issued on the very issue of the deductions claimed as well the material available on records, the AO passed the order u/s 143(3) fully allowing the deductions claimed u/s 54B and 54F, without disturbing the original return of income filed. Then after, the AO assumed the jurisdiction u/s 148 on the ground that the assessee has not fulfilled the conditions prescribed for claiming deduction u/s 54B and 54F of the Act. In appreciation of the materials available on the records, the Hon’ble Court held that this is not the case that the assessee failed to disclose fully and truly all the material facts necessary for the assessment, that the reopening based on the material already on records, it is nothing but a mere change of opinion and not permissible in the eyes of law.  The Hon’ble Court further observed that issuance of notice u/s 148 should be based on the reasons to believe which should have direct nexus with any new information and/or tangible material which has come to the knowledge of the Revenue authorities based on assessment proceedings.  Accordingly, the Court held that the notice u/s 148 falls within the category of change of opinion was to be quashed.(AY. 2015-16)