On writ the proceedings for reassessment was quashed following the order  for the AY. 2004 -05 in Rallis India Ltd. v. ACIT ( 2010) 323 ITR 54 (Bom.) (HC). Held, allowing the petition, that in view of the decision of the High Court in the case of the same assessee for the assessment year 2004-05, there was no justification for reopening the assessment for the assessment year 2005-06 on change of opinion. The reassessment proceedings were invalid.

(Note: SLP of revenue is dismissed, (2018) 408 ITR 28  (St.)