Assessee, a team in India Premium League (Kolkata Knight Riders), had paid various management fees and consultancy fees, including a substantial amount to a foreign entity.  During original assessment proceedings, assessee responded to queries raised by Assessing Officer regarding foreign payments and provided explanations for non-deduction of Tax Deducted at Source (TDS).-Assessment order did not discuss payments made or  non-deduction of TDS. The reassessment proceeding was initiated for failure to deduct tax at source. On writ the Court held that once a query had been raised during assessment proceedings and assessee had responded to it, query raised was deemed to have been considered by Assessing Officer. Therefore, where assessee had submitted during assessment proceedings that no tax was deducted on payment made  and submission so made during assessment proceedings had been accepted by Assessing Officer, reopening of assessment being mere change of opinion did not constitute justification to believe that income chargeable to tax had escaped assessment. The reassessment notice and order disposing the objection is quashed.  (AY. 2016-17)