Dismissing the petition, that at the stage of reopening of the assessment under section 147 the court would not examine the possible additions which the Assessing Officer would make. The scrutiny at that stage would be limited to examining whether the Assessing Officer had formed a valid belief on the basis of the material available with him that income chargeable to tax had escaped assessment. The Assessing Officer had considered the material on record which prima facie suggested that the assessee had sold number of shares in a company which was found to be a shell company indulging in providing bogus claims of long term and short-term capital gains. The assessee had claimed exemption of long-term capital gains of Rs. 1.33 crores by way of sale of shares of such company. The return filed by the assessee were accepted without scrutiny. Since there was no scrutiny assessment, the Assessing Officer had no occasion to form any opinion on any of the issues that arose out of the return filed by the assessee. The concept of change of opinion therefore had no application. (AY. 2013-14)