Allowing the petition the Court held that the reopening of the assessment |is nothing but a change of opinion. The then Assessing Officer, upon due consideration of all the necessary details and information furnished by the assessee had not made any addition in respect of the transaction of receipt of Rs. 6 crores or the repayment of that amount while he made the assessment under section 143(3) . The action of reopening of the assessment merely based on change of opinion was untenable. The notice issued under section 148 was to be quashed and set aside. (AY. 2011-12)