On a writ petition against the order of reassessment making a disallowance under section 69A of the Income-tax Act, 1961 without disposing of the objections of the assessee for the reopening of the assessment. Allowing the petition the Court held that   the reassessment order was unsustainable since it was not based on any new material and constituted a mere change of opinion of the Assessing Officer. There was no new material on the basis of which the Assessing Officer could have formed a subjective satisfaction as to income that supposedly had escaped assessment under section 147. The Department was unable to dispute the fact that the reassessment order merely reproduced the notice under section 148 as a reasoning of the Assessing Officer which was entirely based on a reappreciation of the accounts. The reassessment order and the consequential demand notice issued under section 156 were quashed. (AY. 2012-13)