Assessee received certain sum towards share capital and unsecured loans. After making enquiries the assessment was completed u/s 143((3) of the Act. The assessment was re opened on the  ground that  the assessee was a beneficiary of accommodation entries. However, reasons for reopening assessment furnished by Assessing Officer did not record that there was a failure on part of assessee to disclose, truly and fully, all material facts necessary for carrying out assessment. Tribunal held that  the  Assessing Officer failed to apply its mind independently and that it reopened concluded assessment based on directions of Director of Investigation. Tribunal returned a finding of fact that none of 99 share capital applicants were found in list of accommodation entry providers. Assessee had already been put to scrutiny with regard to infusion of share capital and had furnished relevant information sought by Assessing Officer when initial assessment order was framed under section 143(3) of the Act.   Tribunal quashed the reassessment proceeding.  On appeal dismissing the appeal of the Revenue the court held that  reassessment was due to change of opinion. Order of tribunal quashing the revision order is affirmed. (AY. 2007-08)