Accumulation of income : Where Assessing Officer issued reopening notice against assessee charitable trust on ground that it accumulated certain amount for purpose of for construction of buildings etc., however, assessee utilized said accumulated income for purchase of land which was other than specific purpose, since same issue regarding change in purpose of utilisation of accumulated amount was raised in scrutiny assessment and clarified by assessee, impugned reopening notice was to be set aside being a case of mere change of opinion – St. Mary’s Charity Fund v. Union of India – [2024] 166 taxmann.com 263 (Kerala)