Sec. 37(1) read with section 147 of the Income Tax Act, 1961 – Reassessment – Initiation of reassessment proceedings merely on basis of change of opinion was not justified as AO initiated reassessment proceedings on ground that sales promotion expenses claimed by assessee as deduction was in nature of Capital expenditure and thus, assessee's claim was wrongly allowed in view of fact that there was a complete disclosure of all primary material facts on part of assessee in course of assessment. While allowing the writ petition, High Court quashed the impugned notice as being without jurisdiction. SLP of the revenue dismissed on account of low tax effect. - DY. CIT V/s ASIAN PAINTS LTD. - [2020] 269 TAXMAN 104 (SC)