The assessee-developer’s assessment, completed under S. 143(3), was sought to be reopened after four years on the ground that it had not accounted for the sale consideration of two properties. During the original assessment, a query was raised regarding a turnover mismatch, to which the assessee had explained that it was merely a ‘confirming party’ in the sales made by tenants and not the owner. The High Court noted that since the issue was the subject of a query and a reply, it was considered by the Assessing Officer. It held that the reopening was based on a mere change of opinion, which is not a valid justification for invoking S. 147. Accordingly, the High Court quashed the reassessment notice. (AY. 2014-15)