Assessing Officer reopened assessment on mere ground that expenditure incurred by assessee-company, engaged in business of manufacturing and export of garments, towards sales commission were huge. On appeal the Tribunal held that  reason for reopening was based on same set-of information which was available at time of original assessment proceedings, wherein no disallowance towards sales commission was made, reopening of reassessment based on mere change of opinion was invalid and not permissible. On appeal the Court held that there was no further tangible material available with Assessing Officer which warranted reopening of concluded assessment, thus, no interference was required. (AY. 2005-06)