Assessing Officer issued on assessee a notice under section 148 dated 17-9-2013 seeking to reopen assessment for subject assessment year for reasons that assessee in lieu of cash had received an accommodation entry from a party Transnational Growth Fund Ltd  of Rs. 50 lacs during year and said entry had been shown in various papers seized during search and seizure action conducted on a party  S.K.Jain Group  and, therefore, he had reason to believe that the income of Rs. 50 lacs chargeable to tax had escaped assessment-Assessing Officer accepted explanation of assessee and framed an assessment order under section 143(3) dated 30-3-2015.  Assessing Officer thereafter issued on assessee another notice under section 148 dated 30-3-2018 seeking to reopen the aforesaid assessment for reasons that search action was conduced on 14-9-2010 in case of K. Jain Group    and record seized indicated that K. Jain Group   was involved in providing accommodation entries and assessee was one of beneficiaries of accommodation entry amounting to Rs. 50 lacs. On writ allowing the petition the Court held that   since allegation with regard to source of accommodation entry and amount was similar, both when assessment order dated 30-3-2015 was passed and when notice under section 148 dated 30-3-2018 was issued, it was a clear case of change of opinion and thus invalid in law (AY.2011-12)