Assessee had six industrial undertakings in State of Himachal Pradesh. It claimed deduction under section 80-IC in respect of its two units at rate of 100 per cent. Assessing Officer allowed the claim and passed the order u/s. 143(3) of the Act. Reassessment notice was issued after expiry of four years reopened such assessment for reasons that assessee should have been allowed deduction of 30 per cent and not 100 per cent. On writ allowing the petition the Court held that in assessment order Assessing Officer had discussed on unit wise details of income and expenses claimed under various heads as 80-IC units and non 80-IC units and had also disallowed certain interest hence it was a clear case of change of opinion. Re assessment notice and order disposal of objection was quashed and set aside. Followed PCIT v. Aarham Softronics (2019) 412 ITR 623 / 261 Taxman 529 (SC).  (AY. 2012-13)