Dismissing the appeal of the Revenue the Court held that  since there was full disclosure of interest by the assessee and the Assessing Officer while passing the original assessment order, after discussion, had formed opinion that the interest paid and interest received are not revenue items but capital item, therefore, the subsequent attempt of the Assessing Officer to tax the interest receipt as revenue receipt is clearly based on change of opinion. Therefore the Tribunal has not committed any manifest error of law to set aside the re-assessment proceedings. Thus, once the Assessing Officer has consciously applied his mind for not treating the interest paid and the interest received as revenue item and instead he treated it as capital item, subsequent proceedings under section 147  was clearly based on change of opinion. (AY. 1997-98)