Held that the disallowance of interest proposed in the reasons for reopening of assessment was on a change of opinion. The assessment could not be reopened on the same material, as that would amount to review of the order. Since no new material was brought on record after completion of the assessment under section 143(3) of the Act, the reopening of assessment was not on account of fresh material or change of law, and was liable to be quashed.(AY.2014-15)