Reassessment solely on audit objection sans new material is impermissible. Mere opinion change can't trigger reassessment, as it's a prohibited review.

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....Reassessment proceedings initiated solely based on an audit objection without fresh tangible material are impermissible. A mere change of opinion by the Assessing Officer on the same material cannot be a ground for reassessment, as it would amount to a review, which is not permissible. The corrigendum issued by the Revenue did not disclose any new material warranting reopening of the assessment. Consequently, the reassessment proceedings were quashed, being unsustainable in law.....