Assessee was granted relief/waiver towards overdrafts and other facilities pursuant to one-time settlement with bank.  Assessing Officer initiated reassessment proceedings against assessee to tax said relief alleging that it was revenue receipt. CIT (A) quashed the reassessment order, which was affirmed by the Tribunal. On appeal by revenue the Court held that   during original scrutiny assessment proceedings, Assessing Officer had considered one-time settlement by assessee with its bankers as capital receipt and was not brought under taxation. Since reopening notice was not based on any fresh tangible material and same being issued on same facts which were considered earlier, it clearly amounted to mere change of opinion and, thus, was without jurisdiction. (AY.  2006-07)