Allowing the petition, the Court held that queries were raised during the original assessment, which included questions concerning the sale of the subject land. More particularly, answers were furnished by the assessee, along with the relevant documents and material sought by the Assessing Officer. Clearly, the transaction was examined, and thereafter, an assessment order dated February 28, 2014 was passed. Therefore, it could not be said that the subject transaction was not scrutinised by the Assessing Officer. The Department’s contention that the original assessment order did not disclose any reasoning was untenable in law, as an assessee has no control over how the assessment order is framed. Therefore, this was a case of a change of opinion that cannot form the basis of reassessment. Court also held that the sanction was granted without application of mind. The reassessment notice and order disposing the objection were quashed. (AY.2011-12)