On a writ petition the assessee contended that  the issue of notice under section 148 and initiation of the reassessment proceedings was based merely on a change of opinion.  Allowing the petition the Court held  that the assessment order revealed that the Assessing Officer had applied his mind to the documents and records produced before him by the assessee in the regular assessment which included the balance sheet, profit and loss account and other relevant documents. Therefore, the reopening of the assessment under section 147 was not based on any new material. The notice issued under section 148 was quashed. CIT v. Kelvinator of India Ltd (2010) 320 ITR 561 (SC) followed. (AY.  2009-10)