Change of opinion barred reassessment where the same material was already examined in the original assessment.

Reassessment under sections 147 and 148 was invalid because the original assessment under section 143(3) had already examined the same expenditure material. Reopening on identical facts amounted to a mere change of opinion, and no fresh tangible material was shown to create a reason to believe that income had escaped assessment. The reassessment proceedings were therefore quashed in favour of the assessee.

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Issues: Whether reassessment under sections 147 and 148 of the Income-tax Act, 1961 was valid when the same material had already been examined in the original assessment under section 143(3).

Analysis: The original assessment had called for and considered the relevant expenditure details. Since the very same material formed part of the assessment record, reopening on the same basis amounted to a mere change of opinion. Reassessment requires tangible material giving rise to a reason to believe that income had escaped assessment, and no fresh material was shown to justify reopening.

Conclusion: The reassessment proceedings were invalid and were quashed in favour of the assessee.

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