Assessment was completed under section 143(3). Assessing Officer issued notice under section 148 after 4 years from end of relevant assessment year on ground that income chargeable to tax had escaped assessment doubting genuineness of transaction of issue of shares by assessee-company to its existing shareholders. The assessee filed writ before High Court. Allowing the petition the Court held that since very issue on which Assessing Officer had made reasons to believe that income chargeable to tax had escaped assessment were subject matter of regular assessment proceedings under section 143(3), it was case of change of opinion by Assessing Officer, therefore, impugned notice was to be quashed. (AY. 2012-13)