Reassessment on same seized material is invalid when it amounts to a mere change of opinion.

Reassessment under section 147 was held invalid where it rested on the same seized document and the same facts already examined in the original scrutiny assessment under section 143(3). As no new tangible material or fresh information emerged after the original assessment, reopening could not be sustained merely because a different view was later taken on the same material. The proper remedy for any alleged error lay in other statutory provisions, not in reassessment on a mere change of opinion. The reassessment notice and order were quashed, and the Revenue's appeal failed.

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Issues: Whether reassessment under section 147 of the Income-tax Act, 1961 was valid when it was based on the same seized material that had already been examined in the original assessment, or whether it was barred as a mere change of opinion.

Analysis: The seized document Annexure A-1 had already been considered in the original scrutiny assessment under section 143(3), where the Assessing Officer examined the property-related entries and made additions on that basis. The reassessment was initiated on the very same material and on the same set of facts, without any new tangible material or fresh information coming to light after the original assessment. In such a situation, reopening cannot be justified merely because a subsequent Assessing Officer takes a different view of the same material. The proper course for correcting an allegedly erroneous original assessment would lie in other statutory remedies, not in reopening on the same facts.

Conclusion: The reassessment was invalid as it was based only on a change of opinion, and the reassessment notice and order were rightly quashed. The appeal of the Revenue failed.

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