On writ the Court held that the entire assessment order dated December 28, 2018 was based upon the report of the Directorate General of Goods and Services Tax Intelligence, based upon which the Assessing Officer had assessed the income of the assessee. The same report had been considered as a reason for reopening the assessment in the order, which clearly would indicate that it was not a case of mistake, but was a change of opinion, on the same material, which was not sustainable in law.(AY.2016-17)