Reassessment based on audit objections and the same material fails when it amounts to a mere change of opinion.

Reopening under section 148 was invalid where the original assessment under section 143(3) had already examined the same material and the reasons for reassessment relied only on audit objections and the same profit and loss account entries. No fresh tangible material or independent information supported a new belief that expenditure required disallowance. The reopening was therefore a mere change of opinion on concluded issues, which is impermissible. The notice under section 148 was quashed in favour of the assessee.

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Issues: Whether the reassessment notice issued under section 148 was valid when the original assessment had been completed under section 143(3) on the same material and the reopening was based on audit objections without fresh tangible material.

Analysis: The original assessment had been completed after scrutiny of the material already on record. The reasons recorded for reopening referred to the same profit and loss account entries and proceeded on the premise that certain expenditure should have been added back. No new information or independent material was brought on record to justify a fresh formation of belief. On the facts, the reopening was an attempt to revisit the earlier conclusion on the same material, which is impermissible as a mere change of opinion.

Conclusion: The reassessment was invalid and the notice issued under section 148 was quashed, in favour of the assessee.

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