On writ against reassessment notice,  which was issued  beyond the period of four years from the end of the relevant assessment year in a case in which the original assessment had been made after scrutiny, that the reasons recorded established that the Assessing Officer was proceeding on the basis of material already on record, that there was no allegation even in the reasons recorded that there was any failure on the part of the assessee to disclose true and full material facts, that there was not a single item, no document or material which did not form part of the original assessment proceedings on the basis of which the Assessing Officer had formed a belief that the income chargeable to tax had escaped assessment, and that therefore, the notice of reassessment was not valid. Dismissing the SLP of the Revenue the Court held that from the material on record, it could be seen that the reopening of the assessment was solely on a change of opinion of the Assessing Officer. Order of  High Court affirmed.  High court has referred, Dr. Amin’s Pathology Laboratory (2001) 252 ITR 673 (Bom.)(HC), Raymond Woollen Mills Ltd v ITO (1999) 236 ITR 34 (SC). (AY.2011-12)