Assessment which was  accepted  u/s 143(1) which  was reopened on the ground that  the purchase from  hawala dealers  on the basis of information received from Sales tax department . The AO after detailed verification made an addition of 2.5%  of alleged bogus purchases.AO once again issued notice u/s 147 on the ground that as per N. K. Proteins Ltd 2017-TIOL-23-SC-IT the entire amount should have been disallowed. On writ allowing the petition the court held that  as per settled law, if a claim or an issue had been examined by the Assessing Officer during the previous assessment proceedings, in absence of any material available to the Assessing Officer later on to reassess such income would based on mere change of opinion and, therefore, impermissible. Court also observed  ,the Act recognizes the revisional powers of the Commissioner to be exercised in case where the assessment order is erroneous and prejudicial to the interest of the Revenue. However, the reopening of assessment is an entirely independent and vastly different jurisdiction and cannot be confused with the revisional powers of the higher authority.WP No. 3495 of 2018, dt. 17.01.2019)( AY.2011-12)