Reopening on a mere change of opinion fails when original scrutiny already examined the same claims and no fresh material emerged.

Reopening of a completed scrutiny assessment was held impermissible where the disallowances had already been specifically examined in the original proceedings and no fresh tangible material was brought on record. The reassessment notice under sections 147 and 148 was treated as a mere change of opinion, and the existing coordinate-bench view on the same issue was followed in line with judicial discipline. On that basis, the reassessment foundation failed, the proceedings were quashed, and the assessee succeeded while the revenue's appeal failed.

---

---

Issues: Whether reassessment under sections 147 and 148 of the Income-tax Act, 1961 was valid when the impugned disallowances had already been examined in the original scrutiny assessment.

Analysis: The record showed that the relevant claims had been specifically queried and replied to in the original assessment proceedings completed under section 143(3) read with section 144B of the Income-tax Act, 1961. On the same material, the reassessment notice was issued without any fresh tangible material, making the reopening a mere change of opinion. The Tribunal also noted that the issue had already been decided in the assessee's favour by a coordinate bench, and judicial discipline required that view to be followed.

Conclusion: The reassessment was invalid and the proceedings under sections 147 and 148 of the Income-tax Act, 1961 were quashed in favour of the assessee.

Final Conclusion: The cross-objection succeeded, and the revenue's appeal failed because the reassessment foundation itself was set aside.

Ratio Decidendi: Reopening of a completed scrutiny assessment is impermissible in the absence of fresh tangible material and cannot be sustained when it is founded merely on a change of opinion.

---