Change of opinion cannot justify reassessment by a successor Assessing Officer; no referable question of law remained.

A reassessment cannot be reopened by a successor Assessing Officer merely because he takes a different view from the predecessor on allowance of interest, depreciation on rig machinery, and investment allowance. A substitution of one officer's opinion for another's does not justify reopening where the earlier assessment was based on a considered view. On those facts, no referable question of law survived for a reference under section 256(2), and the reference application was rejected.

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Issues: Whether reassessment could be reopened by a successor Assessing Officer on a mere change of opinion, and whether any referable question of law arose warranting a reference under section 256(2).

Analysis: The assessment had been reopened because the successor Assessing Officer took a view different from that of the predecessor on allowance of interest, depreciation on rig machinery, and investment allowance. Such reopening was founded only on a change of opinion. Where the predecessor's view is sought to be substituted by the successor's contrary opinion, the reopening is not justified. In these circumstances, no referable question of law survived for reference to the High Court.

Conclusion: The reopening was bad in law on a mere change of opinion, and the application under section 256(2) was rightly rejected.

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