Assessee was engaged in business of development of real estate projects.  Assessee filed its return wherein it adjusted interest income against interest expenditure and remaining amount was transferred to work-in-progress account. Assessing Officer completed assessment under section 143(3) accepting assessee’s treatment of interest income. Subsequently, Assessing Officer initiated reassessment proceedings taking a view that interest income earned by assessee had to be taxed as income from other sources. On writ allowing the petition the Court held that since entire question of taxing assessee’s interest income was minutely scrutinized by Assessing Officer during original assessment proceedings, in such a case, in absence of any new material, reopening of assessment would be based on mere change of opinion. Accordingly the reassessment proceeding was quashed. (AY. 2013-14)