A notice was issued under section 148 on ground that genuineness of amount payable to sundry creditors which was pending for long period was not ascertained during original assessment and should have been treated as cessation of liability in terms of section 41(1) and to ought to be added to assessee’s income. On writ the Court held that the Assessing Officer sought to reopen assessment proceedings based on same material facts which were present before him during original proceedings and there was not even a whisper of any additional information. Re assessment based on mere change of opinion is not permissible in view of proviso to section 147 of the Act.  On appeal by Revenue SLP of revenue is dismissed. (AY. 2015-16)