Held that  the  assessee had received notice calling upon it to furnish details of brought forward losses and assessed losses, if any, along with proof and, assessee had provided all details as sought for.  Therefore, reopening of assessment being merely by way of change of opinion relying on same set of primary facts which had been submitted by assessee during original assessment proceedings was to be quashed and set aside. As regards the expenditure  the Assessee had replied to this notice by a communication addressed through assessee’s Chartered Accountants and in said document assessee had provided all details as sought for.  In fact these figures were also mentioned in statement of profit and loss filed by assessee. Therefore, reopening of assessment being merely by way of change of opinion relying on same set of primary facts which had been submitted by assessee during original assessment proceedings was to be quashed and set aside.  (AY.2013-14)