The assessee’s assessment for AY 2013-14 was completed under section 143(3). A notice under section 148 was issued after four years on the grounds that interest income was incorrectly netted off against interest expense and the balance capitalized to Work‑in‑Progress, instead of being offered to tax as ‘Income from other sources’, and that a provision for income‑tax had not been added back. The High Court observed that during the original assessment proceedings, the AO had raised specific queries on these issues, to which the assessee had filed a detailed reply. The Court held that once a query is raised and replied to, it is deemed that the issue was considered by the AO, even if it is not explicitly discussed in the assessment order. Thus, the reopening was based on a mere change of opinion and not on any failure by the assessee to disclose material facts. The reassessment notice was accordingly quashed. (AY. 2013-14)