Reassessment based solely on re-examining existing scrutiny records is an impermissible change of opinion and invalid reopening.

Reassessment under Section 147 requires a bona fide reason to believe that income escaped assessment, based on tangible material or reliable information with a live link to that belief. Where recorded reasons merely re-verify and reappreciate records already examined during the completed scrutiny assessment, without new information or triggering material, reopening constitutes an impermissible change of opinion. The note states that such reopening is invalid and the resulting reassessment is quashed.

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Issues: Whether reopening of the completed scrutiny assessment was valid where it was founded solely on re-verification of existing assessment records without new tangible material.

Analysis: Reassessment under Section 147 requires a bona fide reason to believe that income escaped assessment, founded on tangible material or reliable information having a live link with that belief. The recorded reasons disclosed no new information or triggering material; they merely reflected a fresh verification and reappreciation of records considered in the original scrutiny assessment. Such reopening amounts to an impermissible change of opinion.

Conclusion: The reopening was invalid and the reassessment was quashed in favour of the assessee.

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