Allowing the petition the Court held that there was no tangible fresh material based upon which the Assessing Officer could have reason to believe that income had escaped assessment under section 147. The queries particular to the issue were raised by the Assessing Officer and were answered by the assessee, and upon consideration of all these materials, an assessment order was passed under section 143(3). On the ground that some other view was possible, the Assessing Officer could not have changed his earlier opinion and, based upon such change of opinion, issued the notice under section 148 seeking to reopen the assessment. The notice and the order rejecting the assessee’s objections were set aside.(AY.2016-17)