Reassessment proceedings were sought to be initiated on the ground that the creditors were not genuine. Held that the department had no fresh/tangible material in its possession, which was not there at the time of original assessment, to reach the conclusion of there being an escapement of income. Perusing of the same material, which was there at the time of original assessment, to reopen the assessment proceedings amounts to change of opinion. The reassessment proceedings were to be quashed. (AY. 2007-08)