Reopening assessment under Section 147 invalid when based on mere change of opinion without fresh material

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....The HC allowed the assessee's appeal challenging reopening of assessment under Section 147 of the Income Tax Act. The court held that Section 147 powers cannot be invoked for reviewing completed assessments, as mere change of opinion does not constitute valid reasons to believe. The assessing officer had already considered the disputed aspects during original scrutiny assessment under Section 143, as evidenced by relevant documents. Since the reasons provided for reopening pertained to matters previously examined and decided, the reopening constituted an impermissible review rather than a valid reassessment. The court concluded that without fresh material or information not available during original assessment, reopening based on reconsideration of same facts violates established legal principles governing reassessment proceedings.....