Allowing the petition the Court held the notice under section 148 of the Act dated December 13, 2017 was issued in the name of the amalgamating company instead of the new company. Further, the Assessing Officer after examining threadbare the various issues including the issues as to the keyman insurance premium and disallowance under section 14A of the Act, took a view not to make any disallowance in respect of the keyman insurance premium while framing assessment under section 143(3) of the Act and made a disallowance under section 14A of the Act. It was therefore, apparent that there was a change of opinion by the Assessing Officer to reopen the assessment for the assessment year 2013-14, more particularly, when the issues raised in the reopening assessment were already considered during the assessment proceedings under section 143(3) of the Act. The Assessing Officer did not have jurisdiction to issue the notice under section 148 of the Act, for reopening the assessment for more particularly, when the assessment was sought to be reopened beyond a period of four years.  Accordingly, the notice of reassessment and order disposing of the objection was quashed. (AY.2012-13)