JUDGMENT I. MAHANTY, J. - In the present writ application, the petitioner-company-M/s. Sarda Mines Private Limited has sought to challenge the reassessment notice dated 15.02.2014 issued under Section 43 of the O.V.A.T. Act under Annexure-8. The impugned notice is purportedly being issued based on a Tax Evasion Report No.05 dated 15.02.2014 under Annexure-11 and the aforesaid Tax Evasion Report can be found from the communication dated 14.03.2014 under Annexure-9 series appended to the writ application. 2. It is submitted by Mr. Naveen Kumar, learned Senior Advocate appearing for the petitioner-company that the present case is identical with the judgment dated 20.4.2017 rendered by this Court in W.P. (C) No.24421 of 2012 in the case of M/s. Sarada Mines Pvt. Ltd. vrs. State of Orissa & Ors. (2017 (I) ILR-CUT-949) where, it is submitted that in an identical circumstances, this Court had been pleased to quash the reassessment notice on a finding that the said notices would products of “change of opinion”. It is submitted on behalf of the petitioner-company that a mere change of opinion cannot be a ground for initiating the reassessment notice and is well settled by various judgment of the Hon’ble Supreme Court as considered in the judgment referred hereinabove. 3. Learned Standing Counsel for the Revenue fairly admits that the judgment relied upon by the learned Counsel for the petitioner-company is identical to the case at hand and covers the issues raised in the present writ application. 4. On consideration of the submissions recorded hereinabove and in view of the judgment dated 20.04.2017 rendered by this Court in W.P.(C) No.24421 of 2012, we hold that the impugned notice of reassessment dated 15.02.2014 under Section 43 of the O.V.A.T Act under Annexure-8 is clearly a product of a mere “change of opinion” and hence being without jurisdiction, the same stands quashed. The writ application is accordingly allowed. No costs. K.R. MOHAPATRA, J. I agree. Application allowed.