Commiioner Of Income Tax vs Icici Bank Ltd.

Whether on the facts and in the circumstances of the case and in law the Tribunal was right in holding that the notice for reopening of assessment issued u/s.148 of the Income Tax Act was bad in law as the notice was based on mere change of opinion even though the assessment was reopened within a period of four years and the record shows that the Assessee Company had claimed excess deduction u/s. 36(1)(viii) of the Income Tax Act on income which included non fund base income and income from short term finance? --- Held Yes.