S. 147 : Reassessment – After the expiry of four years – Penny Stock -Share transactions and tax paid on added income – No new tangible material – Accommodation entries – Reconsideration of the material available at the time of original assessment proceedings is tantamount to change of opinion – Reassessment notice and order disposing the objection was quashed. [S. 10(38), 45 69, 148, Art. 226]