Reassessment on change of opinion and prior Tribunal coverage was not interfered with; the appeal failed.

Reassessment was challenged as unsustainable because the issue was already covered by the Tribunal's earlier order in the assessee's own case and the reopening was based on a mere change of opinion. The Tribunal noted that the same material had been considered in the original proceedings and accepted the finding that reassessment had been initiated on that basis. The reassessment was not interfered with, and the appeal failed.

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Issues: Whether the reassessment was sustainable when the issue stood covered by the Tribunal's earlier order in the assessee's own case and the reopening was based on a mere change of opinion.

Analysis: The appeal challenged the CIT(A)'s order for the relevant assessment year. The Tribunal noted that the controversy was already covered by its earlier order in the assessee's own case. It further accepted the finding that the assessment had been reopened on a mere change of opinion, since the Assessing Officer had considered the same material in the original round of proceedings.

Conclusion: The reassessment was not interfered with and the appeal failed.

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