The AO initiated reassessment proceedings on ground that subsidy received by assessee from Government was directly credited to capital reserve account which resulted into non-consideration of such amount for computation of assessee’s book profit. On writ the court held that there was sufficient disclosure in return filed by the assessee with respect to entry in question and same was also noticed by AO during scrutiny assessment  proceedings. Accordingly the Court held that the  reassessment proceedings had been initiated merely on basis of change of opinion hence notice was quashed. (AY. 2012-13)