Assessment can not be reopened merely on the ground of change of opinion of Assessing officer

RELEVANT PARAGRAPH 10. Section 147 of the Act empowers the assessing officer to reopen the assessment in respect of any assessment year, if he has reason to believe that any income chargeable to tax has escaped assessment. The object of reassessment is to assess the correct income. Under section 147 of the Act, the assessing officer can assume jurisdiction to reopen the assessment only if there exists tangible material on the basis of which he forms a reasonable belief that the income chargeable to tax has escaped assessment. 16. In the present case, admittedly, the reopening of the assessment...