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of <h1>Reassessment requires proof of original opinion and tangible material showing income escapement with live link</h1> 'Change of opinion' in assessment proceedings refers to the formulation of a belief by an assessing officer followed by its alteration. Courts must verify whether the original assessment expressed an opinion on matters forming the basis of alleged income escapement before allowing reassessment challenges. Non-speaking, cryptic, or perfunctory assessment orders make it difficult to attribute any opinion to the assessing officer. The concept serves as an in-built test preventing abuse of power, as assessing officers have reassessment powers but not review powers. Reopening assessments requires tangible material establishing income escapement, with reasons having a live link to belief formation.
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