Assessment was completed assessment under S. 143(3) making certain additions to income declared.  After expiry of four years from end of relevant year, Assessing Officer initiated reassessment proceedings on ground that assessee had accepted loan, deposits etc. of Rs. 20 thousand or more in cash in violation of provisions of section 269SS. Tribunal finding that there was no ommission or failure on part of assessee to disclose fully and truly all material facts at time of original assessment and allegation that deposits were unexplained, were not based on any cogent material evidence on record, set aside assessment proceedings  Dismissing the appeal of the revenue the Court held that since initiation of reassessment proceedings was merely based on change of opinion of Assessing Officer, impugned order passed by Tribunal did not require any interference. (AY. 1992 – 93)