Dismissing the petition the Court held that the return filed by the assessee was accepted without scrutiny. Since there was no scrutiny assessment, the Assessing Officer had no occasion to form any opinion on any of the issues arising out of the return filed by the assessee. The concept of change of opinion would, therefore, have no application. This was not a case where the ITO sought to draw any fresh inference which could have been raised at the time of the original assessment on the basis of the materials placed before him by the assessee as regards the receipt of the share capital and share premium from two Kolkata based companies which were subsequently discovered to be shell companies. The subsequent information, on the basis of which the ITO acquired reason to believe that income chargeable to tax had escaped assessment on account of the omission of the assessee to make a full and true disclosure of the primary facts, was relevant, reliable and specific. It was not vague or non-specific. The notice of reassessment was valid. (AY.2011-12)