Dismissing the appeal of the revenue the Court held that,the assessee during the original assessment proceedings had brought the entire details about the sale of the land in Uthandi village and also noted the fact that the Gazette notification issued by the Government of Tamilnadu was very much available when the original assessment was completed and the Assessing Officer had no new tangible material to justify its reopening. Apart from that, the Tribunal noted that in the case of assessee’s spouse, who was also co-owner of the very same property, the property was treated as agricultural land and the assessment was completed under section 143(3) of the Act and the said finding remained undisturbed. This would clearly show that the reopening of the assessment in the instant case was a clear case of “change of opinion” and the Tribunal was justified in quashing the reassessment proceedings. (AY. 2011-12)