AO in the original assessment proceedngs the AO has raised a specif query as regards amortisation of brnad value and allowability of depreciation. The query was replied and after examining the reply the assessment was completed . AO issued notice of reassessment on the ground that income escaped assessment by reason of failure on the part of the assessee to disclose fully and truly all material facts .  On writ the Court held that once the issue is raised in the original assessment and examined by the AO  , issue of notice for same issue will amount to change of opinion hence the reassessment notice is bad in law . Followed CIT v Ketvinator of India Ltd (2010) 320 ITR 561 (SC) GKN Sinter Metals Ltd v ACIT ( 2015) 371 ITR 225 ( Bom) (HC)  (AY. 2014-15)