Reopening on mere change of opinion is impermissible when no fresh tangible material supports reassessment.

Reopening completed assessments under sections 147 and 148 requires a genuine basis to believe income has escaped assessment, supported by new tangible material. Where the assessee had already disclosed the relevant agreements and supporting documents, and the Assessing Officer relied on the same material originally examined, a later notice based only on a different inference amounted to a mere change of opinion. On these facts, reassessment could not be sustained because it was a review of an earlier view rather than action founded on fresh information; the section 148 notice was quashed.

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Issues: Whether notices issued under section 148 of the Income-tax Act, 1961 for reopening completed assessments were sustainable in the absence of new material and whether the reassessment action was vitiated as a mere change of opinion.

Analysis: The returns had disclosed the relevant agreements and supporting material, and the assessment orders themselves referred to those materials. Reopening under sections 147 and 148 requires a genuine basis to believe that income has escaped assessment, supported by new tangible material. On the facts, no fresh material had emerged after the original assessment; the proposed action rested only on a different inference from the same material already before the Assessing Officer. In such a situation, reassessment is impermissible because it amounts to reviewing an earlier view rather than correcting escapement based on new information.

Conclusion: The reopening was invalid as it was founded on a mere change of opinion and not on new material; the notice under section 148 was quashed, and the reassessment challenge failed in the connected appeal.

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