Assessee sold a flat during assessment year. Assessing Officer selected case of assessee for limited scrutiny assessment with regard to investment in flat, capital gain/income on sale of flat and issued various notices under section 142(1) to her.Assessee responded to notices and provided details of flat sold.Assessing Officer passed assessment order stating that in view of material on record no addition on issues was made. Subsequently Assessing Officer issued on assessee notice under section 148A(b) and passed order under section 148A(d) and issued notice under section 148 holding that flat sold was short-term capital asset and gain arising on transfer of such asset was short-term capital gain. On writ  the Court held that  reopening of assessment is  purely on basis of change of opinion of Assessing Officer from that held earlier during course of assessment proceedings and thus not valid. Followed  Siemens Financial Services (P.) Ltd. v. Dy. CIT [2023] 154 taxmann.com 159/457 ITR 647 (Bom)(HC)   (AY. 2018-19)