Re-assessment proceedings cannot be initiated u/s 147 just because of change in opinion

Brief of the case: Madras High Court held in CIT Vs M/s Schwing Stetter India P Ltd that the case only be opened for re-assessment u/s 147 only if there was a tangible material in the hand of AO , it could not be opened just because of the change in the opinion of AO. Facts of the case: The assessee was engaged in the business of manufacturing concrete mixtures, concrete pumps, etc and filed ROI declaring total income of Rs 1,36,15,445/- and the same was selected for scrutiny in which the total income was determined at Rs 1,40,40,250/-.After that AO issued notice u/s 148 for re-assessment on t...