Reassessment cannot rest on the same material already examined; change of opinion and ignored appellate findings invalidate reopening.

Reassessment based on material already available in the original records, without any new tangible material, was treated as an impermissible change of opinion. The recorded reasons showed that the same factual basis was being re-examined from a different angle, and the objection order also failed to consider an intervening appellate order that had already addressed the disputed issues in the assessee's favour. On that basis, the reopening did not satisfy the statutory threshold for reassessment after the prescribed period, and the notice and rejection order were quashed.

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Issues: Whether the notice for reassessment and the order rejecting objections were liable to be quashed on the ground that the reopening was based on the same material already considered in the original assessment and amounted to a change of opinion.

Analysis: The reassessment was founded on material already available in the assessment records, without any new tangible material to justify reopening. The reasons recorded showed that the very same factual basis was being re-examined in a different manner. The subsequent order rejecting objections also failed to consider the intervening appellate order which had already dealt with the disputed issues in favour of the assessee. In these circumstances, the reopening was not supported by the statutory threshold required for reassessment after the prescribed period and was hit by the doctrine that an assessment cannot be reopened merely to take a different view on the same material.

Conclusion: The reassessment notice and the order rejecting objections were quashed and set aside, in favour of the assessee.

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