Assessee-company is  engaged in business of recycling and trading aluminum scrap.  Assessing Officer completed assessment under section 143(3) on 26-8-2016 by allowing certain expenses on account of raising funds and certain sum as IPO (Initial Public Offering) expenditure. After five years department sought to reopen assessment, claiming that those expenses violated section 35D and was not detected by Assessing Office earlier and therefore, escaped assessment. On writ the Court held that when all facts were correctly disclosed and were on record during assessment proceedings for relevant assessment year and Assessing Officer had not consciously taxed income which was now sought to be looked into, it was a clear case of change of opinion and therefore, reassessment notice was  quashed. (AY. 2014-15)