High Court: Re-assessment requires tangible material, warns against unauthorized reviews under guise of reopening.

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....Reopening of assessment - AO has no power to review; he has the power to re-assess. But re-assessment has to be based on fulfillment of certain pre-condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then,in the garb of re-opening the assessment, review would take place - to reopen an assessment tangible material should be there - HC....