The assessee, a non-resident, for AY 2017-18 was assessed under section 143(3), wherein the Assessing Officer had specifically examined the taxability of finance, sales and corporate service recharges received from its Indian associated enterprise and accepted the returned position. Subsequently, reassessment was sought to be initiated on the basis of an audit objection. Though an audit objection may constitute “information” for purposes of sections 148/148A, the High Court held that it does not compel reopening and the Assessing Officer must independently apply his mind and decide whether income has in fact escaped assessment. Since the very issue of taxability of the receipts had already been examined in original scrutiny and there was no fresh tangible material, the reopening amounted to a mere review of the concluded assessment and was based on a change of opinion, which is impermissible under section 147. The Court further held that there was no allegation of failure by the assessee to disclose fully and truly all material facts and, therefore, under the old law preserved by the first proviso to section 149, the extended six-year period was unavailable; limitation remained four years from the end of AY 2017-18, and the impugned notices having been issued beyond that period were time-barred. Accordingly, the notice and consequential proceedings were quashed. (AY. 2017-18)