The assessee’s assessment was completed under section 143(3). Subsequently, the Assessing Officer issued a notice under section 148 to reopen the assessment on the ground that certain designing and concession fees, allowed as revenue expenditure, should have been treated as capital in nature. The High Court noted that during the original assessment proceedings, the Assessing Officer had issued a notice under section 142(1) calling for specific details of these very expenses, and the assessee had furnished a full reply. The Court held that once a query is raised and replied to, it follows that the issue was a subject of consideration by the Assessing Officer. It is not necessary that the assessment order must contain a discussion or reference to every query raised. Therefore, the attempt to reopen the assessment was based on a mere change of opinion and was not a valid ground to believe that income had escaped assessment. The Court quashed the reopening notice. (AY. 2016-17)