Revenue cannot reopen assessment under Section 147-148 based on change of opinion from previously examined facts

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....HC quashed reassessment notice under Section 148 for Assessment Year 2016-17, ruling that revenue lacked valid "reason to believe" income escaped assessment under Section 147. Court held that identical grounds were previously examined during original scrutiny assessment completed on 24.12.2018. Since assessing officer possessed all necessary information regarding the disputed property during original assessment proceedings, the reopening constituted impermissible "change of opinion" rather than discovery of escaped income. Applying Kelvinator precedent, HC determined revenue cannot reassess based on mere reconsideration of previously available facts. The reassessment proceedings were deemed jurisdictionally invalid as they arose solely from revenue's altered perspective on same material already scrutinized. Petition allowed, notice set aside in assessee's favour.....