Change of opinion bars reassessment when all material facts were disclosed and considered in original assessment.

Where all relevant material was disclosed in the original Section 143(3) assessment, reassessment could not be reopened merely because the Assessing Officer later took a different view of the same facts. The High Court held that once the material was before the Assessing Officer and had been examined, the absence of an express finding on every aspect in the assessment order did not imply non-disclosure. Reopening on the same record would amount only to a change of opinion, which is impermissible. The challenge to reopening therefore failed.

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Issues: Whether reassessment could be reopened on the basis of a mere change of opinion when all material facts had been disclosed during the original assessment.

Analysis: The original assessment had been completed under Section 143(3), and the assessee had placed all relevant material before the Assessing Officer, including its explanation regarding the funded interest loan and the non-taxability of the waiver. The Court held that where the material was already before the Assessing Officer and he had applied his mind to it, the fact that the assessment order did not expressly record a finding on every aspect would not justify reopening. The Court rejected the contention that absence of an express discussion in the assessment order implied lack of disclosure. It held that reopening on the same material and on a different view of the very same facts amounted only to a change of opinion.

Conclusion: Reassessment on the stated ground was not permissible, and the objection to reopening failed.

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