Reassessment requires fresh material, not a mere change of opinion on the same assessment record.

Reassessment cannot be reopened on the same material that was already considered in a completed best judgment assessment, particularly where the record had been examined and the taxable figure determined on the then available material. If no fresh material comes to light after the original assessment, reopening based only on a perceived discrepancy in disclosed consumption or receipts amounts to a mere change of opinion. The operative principle is that reassessment must rest on valid new material, not suspicion or conjecture, and reopening on the same record is not sustainable.

---

---

Issues: Whether reassessment proceedings could be initiated and completed on the basis of the same material already considered in the original best judgment assessment, in the absence of fresh material, and whether such action amounted to a mere change of opinion.

Analysis: The original assessment had already proceeded on best judgment and had been affirmed in appeal, showing that the record had been examined and the taxable purchase figure determined on the then available material. The permission to reopen and the consequential reassessment were founded only on the view that the petitioner's cement consumption and contract receipts appeared higher than disclosed. No fresh material coming to the notice of the authority after the original assessment was shown. Reassessment must rest on material that gives rise to a valid basis for reopening and cannot be sustained on suspicion, conjecture, or a mere shift in opinion on the same record.

Conclusion: Reassessment was impermissible as it was founded on a change of opinion without fresh material, and both the reopening permission and the consequential reassessment order were liable to be quashed.

Final Conclusion: The writ petition was allowed and the reassessment action was set aside, restoring the finality of the completed assessment.

Ratio Decidendi: Reassessment cannot be sustained where the authority seeks to reopen a completed assessment on the same material without fresh information, since a mere change of opinion does not constitute a valid basis for reopening.

---