Allowing the appeal the Court held that during the course of scrutiny assessment, the Assessing Officer had applied his mind to this very aspect and had called for details from the assessee in respect of the amount of Rs. 46,00,000 deposited with the police station and after considering the explanation tendered by the assessee did not make any addition in that regard. Evidently, therefore, the Assessing Officer sought to reopen the assessment on a mere change of opinion and hence, even on this count the assumption of jurisdiction on the part of the Assessing Officer was bad in law.( AY.2011-12)