The assessment is  reopened   on ground that assessee was not eligible for deduction under section 80IB(10) as it had failed to complete requirement stated in section 80IB(10) towards time limit for completion of housing project.  During original assessment proceedings, deduction under section 80IB(10)  was subject matter of consideration by Assessing Officer Assessing Officer raised a query regarding same and assessee had replied to it.  There was also a note on deduction under section 80IB(10)  where in  residential buildings in question had been discussed. On writ the court held that   reopening of assessment merely on basis of change of opinion of Assessing Officer from that held earlier during course of assessment proceedings would not constitute justification and/or reason to believe that income chargeable to tax had escaped assessment.   (AY. 2010-11)