Once the AO had consciously applied his mind for not treating the interest paid and the interest received as revenue items but as capital items, his subsequent attempt to tax the interest receipt as revenue receipt in the reassessment proceedings under section 147 is based on change of opinion. There was full disclosure of the interest receipt by the assessee in the original assessment under section 143(3) and AO in the original assessment order, after discussion, had formed an opinion that the interest paid and interest received were not revenue but capital in nature. Thus, the reassessment proceedings are bad in law.(AY. 1997-98)