Recourse to the power under Section 147 cannot be sustained on a mere change of opinion

RELEVANT PARAGRAPH 7. The admitted position before the Court, on the basis of the material on the record, is that by the notice under Section 148 issued on 30th November 2009, the assessment pertaining to the year 2002 ­03 was sought to be reopened after the lapse of four years. Section 147 postulates inter alia that if the Assessing Officer has reason to believe that income chargeable to tax has escaped assessment for any Assessment Year, he may subject to the provisions of Sections 148 to 153, assess or reassess such income and also any other income chargeable to tax which has escaped asses...