Allowing the petition the Court held that the assessment order was passed in case of assessee whereby claim of deduction under section 80P was allowed, reopening of assessment by issue of notice under section 148 without any new information received by Assessing Officer, only with a view to accord a fresh consideration on issue of deduction under section 80P on same set of records being a mere change of opinion was not justified. Reassessment notice and order disposing the objection was quashed. (AY. 2013-14)