Reopening Tax Assessment u/s 147 Invalid Due to Change of Opinion, Not New Evidence, Court Rules.

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....Reopening of assessment u/s 147 - reliance on information that was received by him from the DDIT - not only the aforesaid details of cash deposits in the bank accounts of the assessee were very much there before the A.O in the course of the original assessment proceedings, but in fact the same had duly been considered and accepted by him as the duly accounted sale proceeds of the assessee. On the basis of our aforesaid deliberations, we are of a strong conviction, that as stated by the Ld. AR, and rightly so, as the case of the assessee had been reopened with a purpose to re-visit the assessment on the basis of a mere change of opinion, which we are afraid is not permissible in the eyes of law - AT....