Assessee filed its return of income and assessment was completed accordingly. Assessing Officer issued a reopening notice after expiry of period of four years from relevant assessment year on ground that assessee had imported certain raw materials being off patents APIs from its AE by paying prices far exceeding ALP and, therefore, income had escaped assessment. AO had relied upon third party prices to hold that assessee made excess payment. On writ the Court held that there was nothing to indicate that assessee was aware of prices at which third party companies had imported said raw material. Further, transfer pricing study as submitted by assessee was accepted by TPO and based on said order, Assessing Officer had completed assessment and, thus, there was nothing to indicate that there was any failure on part of assessee to truly and fully disclose any material facts.  Court held that reopening of assessment was merely on basis of change of opinion and  unjustified.  Reassessment notice and order disposing the objection is quashed.  (AY. 2007-08)