Assessment was sought to be reopened  on ground that assessee had not offered to tax value of unsold flats under head income from house property and out of 12 flats sold by assessee, market value for 9 flats was more than agreement value and therefore, provisions of section 43CA(1) were applicable. On writ the Court held that  same issues were raised during assessment proceedings and assessee had also replied to them and thus, same were a subject matter of consideration of Assessing Officer while completing assessment. Therefore, reopening of assessment being merely on basis of change of opinion  hence bad in law. (AY 2017-18)