Change of opinion bars reassessment when previously scrutinised share transactions are reopened without new tangible material or information.

Reassessment under Section 147 cannot reopen matters already examined in the original scrutiny assessment merely because the assessing officer changes opinion. The notes state that specific queries on share transactions were answered with supporting documents and accepted without adverse findings. As the reassessment relied on the same transactions and material, and proceeded on the incorrect premise that no prior scrutiny assessment existed, it lacked new tangible material or information. The reassessment proceedings were therefore invalid as an impermissible review of the completed assessment.

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Issues: Whether reassessment proceedings could be initiated on issues and material already examined during the original scrutiny assessment.

Analysis: Specific queries concerning the assessee's share transactions were raised in the original scrutiny proceedings, and detailed explanations with supporting documents were furnished. The original assessment accepted the return without any adverse finding on those matters. The reassessment was founded on the same transactions and material, notwithstanding an incorrect premise that no prior scrutiny assessment existed. Reassessment under Section 147 cannot be used to revisit or review an assessment on the basis of a mere change of opinion, absent new tangible material or information.

Conclusion: The impugned reassessment proceedings constituted an impermissible change of opinion and were invalid.

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