Allowing the petition the Court held that that  once a query is raised during the assessment proceedings and the assessee has replied to it, it follows that the query raised was a subject of consideration of the Assessing Officer while completing the assessment. It is not necessary that an assessment order should contain reference or discussion to disclose his satisfaction in respect of the query raised.  Court also held that  there was no live link, a sine qua non, between the material before the Assessing Officer and the belief formed regarding escapement of income under section 147 of the Act. Except for a bald statement in the reasons to believe escapement of income that the assessee had entered into sale or purchase of shares with or without actual delivery in recognised stock exchange, there were no details provided. The source of information or what the information itself was, had not been made available to the assessee. Even though it was not referred to in the assessment order for the assessment year 2013-14, the fact that queries were raised and replies were sent by the assessee itself indicated that such issue was a subject of consideration during the original assessment proceedings. Therefore, the reopening of the assessment was merely on the basis of a change of opinion from that held earlier during the course of assessment proceedings. The reasons recorded did not even make an allegation and did not indicate anything cogent or clear that there was failure on the part of the assessee to truly and fully disclose all material facts necessary for assessment. That in the reasons recorded the establishment of a live link between the information received by the Assessing Officer and the formation of his belief that income had escaped assessment was conspicuously missing. The jurisdictional conditions under section 147 had not been met and the reassessment proceedings were nothing but a “change of opinion” which did not constitute justification or reason to believe that income chargeable to tax had escaped assessment. Hence, the notice issued under section 148 after a period of four years for reopening the assessment and the order rejecting the assessee’s objections were unsustainable. (AY.2013-14)