Reassessment is confined to escaped income and related matters; completed assessment items cannot be reopened on a mere change of opinion.

Reassessment under section 147(a) is limited to income that has escaped assessment and to matters having a nexus with that escaped income. It cannot be used to review the completed assessment or to revisit items already accepted merely because the assessing officer later takes a different view. Items allowed in the original assessment remain outside reassessment unless they are directly relatable to the income on which the notice under section 148 was issued. Accordingly, disallowance of previously allowed items in reassessment was not permitted on the basis of a change of opinion alone.

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Issues: Whether, in reassessment proceedings validly initiated for escaped income, the Income-tax Officer can also disallow or add items that had been allowed in the original assessment.

Analysis: Reassessment under section 147(a) is confined to income that has escaped assessment and to matters relatable to the escaped income. It does not permit a reassessment order to become a review of the original assessment on issues that were not the subject of the reopening. Items already accepted in the completed assessment cannot be reopened merely because a different view is taken, unless they bear a nexus to the escaped income that justified the notice under section 148.

Conclusion: The Income-tax Officer could not, in reassessment proceedings, disallow items that had been allowed in the original assessment only on the basis of a different opinion.

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