Held  that the Department never accepted the retraction statement filed by the assessee on February 14, 2018. There was a prima facie material available in the form of statement recorded under section 131 of the Act from the partner in view of the bogus purchase said to be recorded by the assessee in its books of account, coupled with certain other documents to suggest that income had escaped assessment. With a view to examine these materials which came to the knowledge of the Assessing Officer subsequent to the original assessment, the reassessment proceedings were initiated. The doctrine of “change of opinion” could not act as an embargo for exercise of power vested under section 147 of the Act. On merit the Tribunal held that the  authority erred in holding that the assessee had inserted bogus purchase into his accounts without bringing on record any evidence to hold that entire transactions were not genuine and had relied only upon the statement of one of the partner recorded on February 8, 2018, which was later retracted by all the partners on February 14, 2018 within short date of 6 days. This had not at all considered by the Assessing Officer. The Assessing Officer and the Commissioner (Appeals) did not mention this retraction statement in their order. It was the duty of the Assessing Officer to consider the letter in true perspective and to comment on it which he failed to do so. The assessment having been framed by the Assessing Officer without considering the retraction of statement filed by the assessee, the addition could not be sustained. That the acceptance by the assessee of the addition in one assessment year could not lead to a conclusion that in all these assessment years, the assessee had inserted bogus purchases in a similar way. The principle of estoppel could not be applied. The case of the assessee was to be examined in the light of evidence brought on record and in the present case, there was no evidence brought on record with regard to bogus purchase or creation of any undisclosed assets by the assessee in all these assessment years.  That addition could be made only when it is shown by the evidence brought on record that the books of account are not reliable as there are material errors and omissions existed therein. There should be concrete evidence for considering the purchase entries in the books of account as bogus. In the present case, the sales and purchase shown by the assessee lead to profit and the profits declared by the assessee progressively increased from year-to-year and without any material to suggest that they were bogus it could not be said that the purchases were bogus. That once the statement recorded under section 131 or 131(1A) or 133A of the Act was retracted by the assessee, the Assessing Officer without rejecting the books of account could not make any additions towards bogus purchases. Accordingly, the addition made on the premise of bogus purchase in all these assessment years  were  deleted.(AY. 2012-13 to 2015-16, 2017-18)