Change of opinion cannot justify reassessment where full primary facts were disclosed and the issue was already decided.

Reassessment under section 147(b) could not be initiated on a mere change of opinion where the assessee had disclosed all primary facts. The Income-tax Officer had originally accepted that synthetic resins fell within "petrochemicals", and the later reopening was based only on a revised view supported by a CBDT circular and a Commissioner's memorandum. A reassessment cannot be founded on the same disclosed material once the issue has already been decided. Reopening was therefore not warranted, and the Revenue's reference was declined.

---

---

Issues: Whether reassessment under section 147(b) of the Income-tax Act, 1961 could be initiated merely on a change of opinion based on a CBDT circular and a Commissioner's memorandum when the assessee had disclosed all primary facts.

Analysis: The assessee had placed the relevant primary materials before the Income-tax Officer, who had originally accepted that synthetic resins fell within the expression "petrochemicals". The later attempt to reopen the assessment rested only on a revised view of the same matter, supported by a circular and a memorandum. A mere change of opinion on an issue already decided on disclosed facts does not furnish jurisdiction to reopen under section 147(b).

Conclusion: Reopening was not warranted. The reference sought by the Revenue was declined and the petitions were dismissed, in favour of the assessee.

---