The assessment was completed under section 143(3) of the Act. Reassessment notice was issued   for the  reason that interest paid on loan borrowed by assessee for purchase of shares of a company so as to have controlling stake in said company and not for business purpose was to be capitalised and could not be allowed as deduction.  On writ allowing the petition the Court held that   on the same issues of investment and interest on loans taken was subject matter of a query raised by Assessing Officer during original scrutiny assessment and that assessee had also addressed a communication to give an explanation in regard to allowability of interest and other expenditure as revenue expenditure. After considering submissions of assessee, assessment order was passed. Accordingly  the  notice to reopen assessment was merely on basis of change of opinion of Assessing Officer   and is quashed and set aside. (AY. 2003-04)