No reassessment to disallow exp. due to verdict of SC in other case if impugned issue was examined i

IT: Where Assessing Officer and Transfer Pricing Officer were not only aware of payment of royalty but had taken same into consideration at every stage, reopening of assessment on ground that on account of Supreme Court's ruling part of royalty was to be treated as capital expenditure, would be case of change of opinion which is not permissible in law