During the scrutiny assessment, the AO sought an explanation regarding alleged cash payments to “Majee Group”. The assessee denied any connection with the entity, and as no verifiable material was available, the issue was dropped while completing the assessment under section 143(3) read with section 144B. Subsequently, based on fresh information from the Investigation Wing and Insight Portal/TAS, reassessment proceedings were initiated under sections 148A and 148. Held that reopening was valid as it was based on new tangible material not available during the original assessment. Since no opinion had been formed earlier on the issue, the reassessment was not a case of mere change of opinion. (AY. 2021-22)