Reassessment cannot rest on a mere change of opinion; external information is required to reopen an assessment.

Reassessment under section 147(b) was held invalid because the Assessing Officer relied only on a different view of the same material already examined in the original assessment. No information from an external source was shown, and a mere change of opinion could not justify reopening. The assessment was therefore not liable to be reopened, the assessee succeeded on the preliminary issue, and the revenue appeal failed without any examination of the merits.

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Issues: Whether the reopening of the assessment under section 147(b) of the Income-tax Act, 1961 was valid when it was founded on a mere change of opinion and not on information from an external source.

Analysis: The recorded reasons showed that the Assessing Officer sought to revisit the earlier allowance of relief under section 80J on the view that the capital computation was incorrect. The record did not disclose any information coming from an external source; the reassessment was based only on a different view of the same material already considered in the original assessment. A reopening under section 147(b) requires information and cannot be sustained on a mere change of opinion.

Conclusion: The reopening was invalid and the assessee succeeded on the preliminary issue.

Final Conclusion: The assessment could not be reopened on the material relied upon, and the dismissal of the revenue appeal followed without examination of the merits.

Ratio Decidendi: Reassessment under section 147(b) cannot be sustained on a mere change of opinion and must rest on information from an external source.

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