Dismissing the writ petition the Court held that a perusal of the reasons recorded by the Assessing Officer showed that after considering the report of the Assistant Director of Income-tax the Assessing Officer had conducted an investigation and had gone through the Income-tax return and other related documents of the assessee and had observed that the assessee was a beneficiary of bogus accommodation entries to the tune of Rs.6,94,540. Prior to issuing the notice in question, the Assessing Officer had not formed any opinion regarding the reasons on which the notice under section 148 of the Act had been issued and, therefore, it was not a case of “change of opinion”. The notice of reassessment was valid. (AY. 2015-16)