Held  that the assessee’s submissions showed that that it had disclosed details, nature and accounting of the Central subsidy sanctioned and released by the Government for setting up the small hydro project under the renewable energy scheme of the Ministry of New and Renewable Energy, but no addition was made by the Assessing Officer after making a detailed examination of the documents. Thus, the reassessment proceedings were merely done on the Assessing Officer’s change of opinion after completing the original assessment on due consideration of the facts. It was well-settled law that the Assessing Officer could not invoke sections 147 and 148 merely on a change of opinion. As the reassessment proceedings were initiated by the Assessing Officer under section 147 / 148 on a mere change of opinion and review, the assessment order is quashed.Tribunal also held that   subsidy  received on renewable energy scheme to set up small hydro projects is  capital in nature and  not income.  (AY.2012-13, 2013-14)