Allowing the petition the Court held that the reasons recorded for the proposed reopening an assertion that the assessee had suppressed facts was singularly lacking. What accentuated the situation was the fact that after the initial scrutiny assessment under section 143(3) of the Act, the assessee had preferred an appeal before the Commissioner (Appeals) and thereafter pursuant to the order passed by the Commissioner (Appeals), the assessment was finalised. In this context, the assertion of the assessee that it had furnished an explanation and submitted documents in response to the multiple notices at the stage of initial assessment could not be controverted. A bare perusal of the reasons indicated that the exercise was influenced by a mere change of opinion. The notice of reassessment was not valid. (AY. 2003-04)