Assessment couldn't be reopened on basis of investigation report as it would amount to change of opi

IT : Where Assessing Officer completed original assessment of assessee for assessment year 2005-06 under section 143(3) on 24-12-2007 and subsequently he issued on assessee a notice for reassessment on basis of investigation report dated 13-3-2006 received from investigation wing, since reasons to believe did not state that investigation report was not with Assessing Officer when he completed original assessment, attempt to reopen assessment was result of a change of opinion