ORDER Harsha Devani, J. 1. The appellant - revenue in this appeal under section 260A of the Income Tax Act, 1961 (hereinafter referred to as "the Act") has challenged the order dated 2nd February, 2015 made by the Income Tax Appellate Tribunal, Ahmedabad 'B' Bench (hereinafter referred to as "the Tribunal") in ITA No. 1957/Ahd/2011 by proposing the following question stated to be a substantial question of law:-- [A] "Whether the ITAT has erred in law and on facts in upholding the decision of CIT(A) whereby CIT(A) annulled the re-opening of assessment proceedings by stating that it was a mere change of opinion based on the opinion/views of audit party?" 2. The assessment year is 2005-06 and the corresponding accounting period is the previous year 2004-05. In this case, the assessee filed its return of income for the assessment year together with an audit report on 27th October, 2005 declaring total income at Rs. 2,89.980/- which was processed under section 143(1) on the returned income. The matter was taken up for scrutiny and assessment came to be framed under section 143(3) of the Act vide order dated 27th December, 2006 determining a total income of Rs. 2,99,980/-. Subsequently, the Assessing Officer reopened the assessment by issuing notice under section 148 of the Act on 22nd March, 2010. The reasons recorded for reopening the assessment read thus:-- "The assessee has trading business in agriculture produces has shown shortage of 2.52% as against 0.0092% to 0.35% shown by other 5 parties in audit memo. This resulted in lower Sales and lower profits. The audit party considered 0.50% as reasonable shortage and disallowed excess shortage and disallowed excess shortage of 2.02%. It has resulted into the underassessment to the tune of Rs. 33,04,144/-. So, the most suitable remedial action is U/s.147 of the IT Act." The Assessing Officer calculated the shortage in excess of 0.5% which came to Rs. 34,73,180/- and disallowed the same out of the total shortage claimed by the assessee and added the same to the total income of the assessee. 33,04,144/-. So, the most suitable remedial action is U/s.147 of the IT Act." The Assessing Officer calculated the shortage in excess of 0.5% which came to Rs. 34,73,180/- and disallowed the same out of the total shortage claimed by the assessee and added the same to the total income of the assessee. The assessee carried the matter in appeal before the Commissioner (Appeals) who allowed the appeal and held that the reopening in this case was a clear case of change of opinion based on conjectures, a case where no new information was there and a case where the opinion was not of the Assessing Officer but clearly of the audit party and accordingly, directed that the reassessment proceedings be annulled. Revenue carried the matter in appeal before the Tribunal but did not succeed. 3. Heard Mr. Sudhir Mehta, learned senior standing counsel for the appellant and Mr. S.N. Divatia, learned advocate for the respondent. 4. As can be seen from the reasons recorded, all that is reflected therein is the opinion of the audit party that 0.5% should be considered as reasonable shortage and excess shortage should be disallowed and accordingly an excess shortage of 2.02% is required to be disallowed. It is the opinion of the audit party that excess shortage had been disallowed resulting into an underassessment to the tune of Rs. 33,04,144/-. Thus, from the reasons recorded, there is nothing to disclose that the Assessing Officer has formed any opinion that income chargeable to tax has escaped assessment for the reasons recorded therein. All that the reasons recorded reflect is the opinion of the audit party. Section 147 of the Act provides that if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may reopen the assessment in terms thereof. Thus, it is the satisfaction of the Assessing Officer which is necessary for reopening the assessment. In the present case, on a plain reading of the reasons recorded, it is evident that no such satisfaction has been recorded by the Assessing Officer. The Commissioner (Appeals), therefore, rightly came to the conclusion that this is a case of clear change of opinion based on conjectures and a case where the opinion was not of the Assessing Officer but clearly of the audit party. The Commissioner (Appeals), therefore, rightly came to the conclusion that this is a case of clear change of opinion based on conjectures and a case where the opinion was not of the Assessing Officer but clearly of the audit party. The Tribunal, therefore, did not commit any error in upholding the order passed by the Commissioner (Appeals). The impugned order passed by the Tribunal, therefore, does not give rise to any question of law, much less, a substantial question of law warranting interference. The appeal, therefore, fails and is accordingly dismissed.