The assessee is engaged in the business of manufacture of Polyester and Texturised/Twisted yarn and management consultancy. In the original assessment proceedings  the  AO  treated the waiver towards overdrafts and other facilities pursuant to one-time settlement with bank  is not taxable. AO  thereafter initiated reassessment proceedings and taxed the receipt. Tribunal quashed the reassessment proceeding. On appeal by the revenue the court held that, 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. Order of Tribunal is affirmed. (AY. 2006-07)