Reassessment reopening needs fresh tangible material; a mere change of opinion cannot justify reopening completed assessments.

Reopening of completed assessments under section 147 requires fresh tangible material forming an objective reason to believe that income has escaped assessment; a mere change of opinion on material already on record is insufficient. As the reassessment reasons rested on the same balance-sheet material that had already been considered in the original section 143(3) assessments, no external or new material supported jurisdiction under section 148. The reassessment notices were therefore invalid, the reassessment orders were unsustainable, and the assessee succeeded on the reopening challenge.

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Issues: Whether the reassessment notices issued under section 148 were valid in the absence of new tangible material and whether the completed assessments could be reopened merely on a change of opinion.

Analysis: The assessments for the three years had already been completed under section 143(3), and the reasons for reopening were founded on the same balance-sheet material that was already on record. No external or fresh material was shown to have triggered the formation of belief that income had escaped assessment. In such circumstances, the reopening could not be justified as a valid exercise under section 147, since the jurisdiction to reopen requires objective material and not a mere review of the earlier view taken on the same facts.

Conclusion: The reassessment notices were invalid and the reassessment orders were unsustainable; the assessee succeeded on the jurisdictional challenge.

Final Conclusion: The reassessment was quashed, the Revenue's appeals did not survive, and the assessee obtained relief on the reopening issue.

Ratio Decidendi: Reopening of a completed assessment requires fresh tangible material forming a bona fide reason to believe that income has escaped assessment, and cannot rest on a mere change of opinion on material already on record.

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