That is the issue of bogus purchases and accommodation of entries and that there is a clear change of opinion by the AO. He submitted that, in the reasons supplied along with first reopening notice, the issue of bogus accommodation of entries regarding purchases was discussed. The reasons given for second reopening notice reproduced above also refer to the said fact. The reasons also refer to a decision of the Supreme Court in the case of N.K. Proteins Ltd. vs. Dy. CIT 2017-TIOL-23-SC-IT. Even this decision was before the AO in the proceeding pursuant to first reopening notice. The petitioner, along with its objections, placed explanatory note as to how the said decision of the Supreme Court in N.K. Proteins (supra) did not apply to the facts of the case. Therefore, this aspect was also considered when the proceeding under the first reopening notice was conducted. In the circumstances, the contention of the petitioner that the impugned reopening notice is issued only on mere change of opinion will have to be accepted.