Change of opinion cannot justify reopening a completed scrutiny assessment when all material facts were already disclosed.

A completed scrutiny assessment under section 143(3) cannot be reopened under sections 147 and 148 merely because the Assessing Officer later prefers a different view on the same material already disclosed, including the sale deed and capital gains particulars. Once the assessee has fully and truly placed the relevant facts before the Assessing Officer, a presumption arises that the original assessment was made on application of mind. The absence of a detailed discussion in the assessment order does not, by itself, justify reassessment. Reopening based only on a change of opinion is invalid, so the notice under section 148 was quashed and the reassessment proceedings could not stand.

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Issues: Whether reopening of the completed assessment under sections 147 and 148 was valid when the material relating to the sale deed and capital gains computation had already been placed before the Assessing Officer in the original assessment under section 143(3).

Analysis: The original assessment had been completed under section 143(3) after the assessee had disclosed the sale deed and the relevant particulars for computing capital gains. Once a regular assessment is framed under section 143(3), a presumption arises that it was made on application of mind. Reopening cannot be sustained merely because the assessment order does not contain a detailed discussion on the point, and a subsequent different view on the same material amounts to change of opinion. In these circumstances, the reasons recorded for reopening did not disclose any failure by the assessee to fully and truly disclose material facts.

Conclusion: The reopening under sections 147 and 148 was invalid and the notice under section 148 was quashed. The assessment was annulled, and the assessee succeeded.

Final Conclusion: The reassessment proceedings could not be sustained because they were founded only on a change of opinion after a completed scrutiny assessment.

Ratio Decidendi: A completed assessment under section 143(3) cannot be reopened under sections 147 and 148 merely because the Assessing Officer later takes a different view on the same material already disclosed and considered; absence of detailed discussion in the original order does not by itself justify reassessment.

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