On writ allowing the petition the Court held that once all materials which were furnished by the assessee were subject matter of consideration in the assessment order being passed under s. 143(3), in such event in the absence of any fresh tangible material, the AO could not have issued a notice under s. 148 to reopen the assessee’s assessment for the reason that the AO would not have jurisdiction under the garb of reassessment under s. 147, to reopen the assessee’s assessment merely on the basis of change of opinion and/or review the assessment order passed against the assessee. (AY.2014-15)