Reassessment on a change of opinion is invalid where the same claim was already examined in original assessment.

Reassessment under section 147 is invalid where the same wage revision arrears claim was already specifically examined in the original scrutiny assessment and again considered in rectification proceedings. The text notes that the assessing officer had queried the claim under section 143(3), accepted it, and later dropped proposed section 154 proceedings after considering the audit objection. Reopening on the same material was therefore treated as a mere change of opinion, not a fresh or valid reason to reopen the assessment, and the revenue's challenge failed.

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Issues: Whether reassessment initiated under section 147 of the Income-tax Act, 1961 was valid when the wage revision arrears claim had already been specifically examined in the original assessment and in subsequent rectification proceedings.

Analysis: The issue of wage revision arrears was specifically queried during the original assessment under section 143(3) and was answered by the assessee. The assessment was completed after the assessing officer accepted the claim. Thereafter, on an audit objection, rectification proceedings under section 154 were proposed, but the objection was considered and the proceedings were dropped. The reassessment was then reopened on the same material. In these circumstances, the reopening was founded on the same issue already examined earlier and amounted to reopening on a change of opinion rather than on any fresh or valid reason.

Conclusion: The reassessment under section 147 was invalid and bad in law. The dismissal of the revenue's challenge to the order of the CIT(A) was correct, and the finding went in favour of the assessee.

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