Assessing Officer issued notices to loan providers under section 133(6) for verification and confirmation of loan transactions and said parties responded and disclosed their identity, explained creditworthiness, genuineness of transactions, source of funds, etc. Assessing Officer after considering responses of loan providers and all documents and explanations submitted by assessee passed assessment order under section 143(3). Thereafter Assessing Officer reopened above assessment for reasons that as assessee offered no explanation about nature and source of loan and creditworthiness of creditors and genuineness of transactions had not been explained, source of loan remained unexplained and needs to be added to total income of assessee. On writ the Court held that  since entire issue which was subject matter of reasons recorded had been raised during assessment proceedings, response obtained from assessee and assessee’s explanation had been accepted by Assessing Officer reopening was purely based on change of opinion and, thus, not sustainable.  (AY.  2014-15)