Change of opinion cannot justify reassessment when reopening a completed assessment on the same material for deduction claims.

Reassessment under section 147 cannot be sustained where the Assessing Officer reopens a completed assessment merely on a change of opinion about the allowability of deduction under section 80HHC. Although escaped income may justify reopening, a later officer cannot invoke reassessment simply because he disagrees with the earlier computation on the same material. A legally sustainable basis showing escapement of income is required, and a mere revision of view does not meet that standard. The reopening was therefore held unjustified and the matter was decided in favour of the assessee.

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Issues: Whether reassessment could be sustained when the Assessing Officer reopened the completed assessment merely on a change of opinion regarding the allowability of deduction under section 80HHC.

Analysis: The assessment had already been completed, and the later reassessment proceeded on the view that the earlier computation of the deduction was incorrect. The Court held that although escaped income can justify reopening under section 147, the power cannot be used simply because a subsequent Assessing Officer disagrees with the earlier assessment. A mere revision of opinion on the same material does not furnish a valid basis for reassessment.

Conclusion: The reopening was unjustified and the issue was decided in favour of the assessee.

Ratio Decidendi: Reassessment under section 147 cannot be initiated merely because a later Assessing Officer takes a different view on the same assessment material; there must be a legally sustainable basis showing escapement of income.

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