During relevant year, assessee had claimed expenses incurred till opening of new stores under head store launching expenses in its books of account .Such expenditure incurred by assessee prior to launching a new retail store comprised of cost of advertisement and promotion, employee recruitment and training, travel etc.. which was allowed as revenue expenditure . Assessing Officer sought to reopen assessment to disallow store launching expenses incurred during year on ground that these were classifiable as capital expenditure and not as revenue expenditure . On writ the Court held that   subsequent to assessment, no new information or fact had come to notice of Assessing Officer so as to initiate proceedings under section 148 . Assessing Officer had in his possession all primary facts when original assessment order was passed and on consideration of material on record, and explanation offered, he had arrived at a final conclusion that assessee was entitled to deduction as claimed .Reopening of assessment on basis of very same material being a clear case of change of opinion is  not justified .  ( AY. 2004 -05 )