The assessee acquired the customer care parts business by a business transfer agreement dated April 26, 2007. The assessee claimed that it was entitled to depreciation on the vendor and dealer network and the details of depreciation were disclosed in the tax audit report annexed with the return of income. Submissions were made on various dates along with written submissions, which were filed before the AO to justify its claim to depreciation on the vendor and dealer network and goodwill. The assessment was completed under S. 143(3) of the Act .  Subsequently there was an audit objection raised by the audit party of the Comptroller and Auditor General regarding the claim for depreciation on the dealer and vendor network and goodwill. The AO  issued a notice of reassessment. On a writ  allowing the petition the Court held that the AO  was justified in holding that the vendor and dealer network rights and the goodwill acquired by the assessee pursuant to the business transfer agreement dated April 26, 2007, would qualify for depreciation under section 32 and the assessment was completed considering the claim for depreciation after seeking for clarification from the assessee. The reasons assigned by the AO to reopen the assessment was nothing but a clear case of change of opinion. It was manifestly clear that the AO had issued the reassessment notice on the ground of direction issued by the audit party. The notice was not valid.( AY. 2010-11)