The reassessment was initiated on the allegation that the assessee had failed to deduct tax at source from reinsurance premium paid to non-resident reinsurers. The Tribunal held that the issue had been thoroughly examined during the original assessment proceedings and the Assessing Officer had formed an opinion after detailed enquiry. As there was no fresh tangible material and no failure on the part of the assessee to disclose fully and truly all material facts, the reopening amounted to a mere change of opinion and was liable to be quashed. (AY. 2008-09 to 2014-15).