Change of opinion bars reassessment when original assessment was made after full disclosure and no new material emerged.

Reassessment under section 147 could not be sustained where the original section 143(3) assessment was completed after full disclosure of primary facts, including accounts, audit report and deduction details, and the Assessing Officer had already applied his mind to those materials. With no new tangible material brought on record, reopening on the same facts amounted to a prohibited review of the earlier assessment and was vitiated by mere change of opinion. The reassessment was therefore quashed.

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Issues: Whether the reassessment under section 147 of the Income-tax Act, 1961 was valid when the original assessment under section 143(3) had been completed on full disclosure of primary facts and no new tangible material was brought on record, or whether the reopening was vitiated by mere change of opinion.

Analysis: The original assessment records showed that the assessee had furnished the relevant accounts, audit report and deduction details, including the claim under section 80IA, and the Assessing Officer had applied his mind to those materials. In the reassessment, no fresh material was shown to justify a different view on the same set of facts. Reopening an assessment in such circumstances would amount to a review of the earlier completed assessment, which is not permitted under section 147 where the earlier order under section 143(3) was made after consideration of the material placed on record.

Conclusion: The reopening was invalid, being based only on a change of opinion, and the reassessment was liable to be quashed.

Ratio Decidendi: A reassessment under section 147 cannot be sustained where the original assessment under section 143(3) was completed after full and true disclosure of material facts and no new tangible material exists to justify reopening; mere change of opinion is not a valid basis for reassessment.

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