Sec. 147 & 148 of Income Tax Act, 1961 — Reassessment — Once having revealed from the record that the assessee disclosed full and complete facts and on scrutiny, at the time of original assessment all these details are examined, no change of opinion is permissible merely because there was some error either on the part of the Assessing Officer himself or because he choose not to opine on the issue or even when he changes his mind and interprets the material or law otherwise than what was done by him. Notice issued under section 148 by the Assessing Officer is beyond the period of four years from the end of relevant assessment year and did not comply with the requirements of proviso to Section 147, the Assessing Officer had no jurisdiction to reopen the assessment proceedings which were concluded on the basis of assessment under Section 143 [3] and therefore, on this short count alone, the impugned notice is liable to be quashed and set-aside — Dhirendra Hansraj Singh vs. Asstt. CIT [2020] 421 ITR 176 (GUJ)