Section 56, 147 & 148 of the Income-tax Act, 1961—Reassessment—In a situation where the Assessing Officer during scrutiny assessment, notices a claim of exemption, deduction or such like made by the assessee, having some prima facie doubt raises queries, asking the assessee to satisfy him with respect to such a claim and thereafter, does not make any addition in the final order of assessment, he can be stated to have formed an opinion whether or not in the final order he gives his reasons for not making the addition . An assessment previously framed cannot be reopened on a mere change of opinion. It is stated that the power to reopening cannot be equated with review — Rubix Trading P. Ltd. vs. ITO [2020] 421 ITR 330 (BOM)