The assessment of the petitioner was completed u/s 143(3) of the Act. Reassessment notice was issued on the ground that as per ITS data petitioner sold 55 flats and no turnover related to said sales was disclosed in his income tax return. On writ allowing the petition the Court held that   in scrutiny assessment petitioner had filed detailed response with respect to ITS data which was accepted by Assessing Officer. The Assessing Officer was aware of issue of ITS data and had applied his mind in regular assessment proceeding of petitioner, it would not be open for Assessing Officer to reopen assessment after a period of 4 years in absence of material to show escapement of income merely on basis of change of opinion. Notice for reopening assessment was to be quashed. (AY. 2012-13)