No reassessment by AO due to change of opinion that assessee wasn’t acting as an agent of State Govt

IT : Where Assessing Officer on basis of material on record, accepted assessee's claim that it being an agent of State Government, was not required to offer any income to tax from development of a new town project, he could not initiate reassessment proceedings after expiry of four years from end of relevant year merely on basis of change of opinion that assessee was not acting as agent of State Government in respect of project in question