Reassessment on the same record fails where reopening is based only on change of opinion, not fresh information.

Reassessment under section 147(b) was held unsustainable where the assessee's bonus set-on reserve had already been disclosed in the accounts and examined in the original assessments. The recorded reasons showed only a deeper scrutiny of the same material, without any fresh external information coming into the assessing officer's possession after the original assessment. On those facts, the reopening was treated as a mere change of opinion rather than a valid basis for belief that income had escaped assessment, so the notices under section 148 and the reassessment orders were quashed.

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Issues: Whether the reassessment proceedings initiated under section 147(b) of the Income-tax Act, 1961, and the consequential notices under section 148 were valid, where the basis was a re-examination of the assessee's bonus set-on reserve shown in the original records.

Analysis: The subject-matter of the reassessment had been disclosed in the assessee's accounts and had already been examined in the original assessments and in earlier proceedings. The recorded reasons for reopening showed only a deeper scrutiny of the same materials and did not disclose any fresh external information coming into the possession of the assessing officer after the original assessment. On the facts found, the reassessment was founded on a change of opinion on the same record rather than on statutory information giving rise to a belief that income had escaped assessment.

Conclusion: The reopening under section 147(b) was not attracted and the notices under section 148, together with the reassessment orders, were quashed, in favour of the assessee.

Ratio Decidendi: Reassessment under section 147(b) cannot be sustained where the assessing officer merely reconsiders the same material already on record and no subsequent information comes into possession to justify a reason to believe that income has escaped assessment.

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