https://www.taxtmi.com/caselaws?id=36153 Reassessment under section 147(b) could not be initiated on a mere change of opinion where the assessee had disclosed all primary facts. The Income-tax Officer had originally accepted that synthetic resins fell within "petrochemicals", and the later reopening was based only on a revised view supported by a CBDT circular and a Commissioner's memorandum. A reassessment cannot be founded on the same disclosed material once the issue has already been decided. Reopening was therefore not warranted, and the Revenue's reference was declined. en-us Mon, 05 Feb 1979 00:00:00 +0530 Fri, 19 Mar 2010 16:19:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36153 Reassessment under section 147(b) could not be initiated on a mere change of opinion where the assessee had disclosed all primary facts. The Income-tax Officer had originally accepted that synthetic resins fell within "petrochemicals", and the later reopening was based only on a revised view supported by a CBDT circular and a Commissioner's memorandum. A reassessment cannot be founded on the same disclosed material once the issue has already been decided. Reopening was therefore not warranted, and the Revenue's reference was declined. Case-Laws Income Tax Mon, 05 Feb 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36153