Tribunal held that the Assessing Officer was well aware of the fact that the gold belonging to family members was taken by the assessee as metal loan way back before 2001 itself and the assessee was consistently following the practice of including the metal loan in its stock register as belonging to family members without showing it as its own stock nor showing the value of gold as capital contribution/liability. Hence, the Assessing Officer did not have any reason to doubt the genuineness of explanation given by the assessee with regard to the unreconciled 17.319 kgs. of gold. The expression “unreconciled” was a misnomer and the Assessing Officer had reopened the assessment on mere change of opinion. There was no material brought on record to support the view of the Assessing Officer. The reopening of assessment for all the years under consideration was on account of “change of opinion” and not valid. (AY. 2006-07 to 2012-13)