Allowing the petition the Court held that  the very issue that such transaction was a subject of consideration by the Assessing Officer during the original assessment proceedings and the assessee had responded to with all the relevant details of transactions with the company in question. Such change of opinion could not constitute justification or reason to believe that the income chargeable to tax had escaped assessment. Hence, the notice and  the order rejecting the assessee’s objections and the subsequent assessment order were quashed and set aside.(AY.2013-14)