The assessee is a Public Charitable educational institution assessed as AOP which has claimed exemption under Section 10(23C)(iiiab) of the Act. The AO reopened the case of assessee on the basis of audit objections as he noticed that the assessee was not eligible for exemption under Section 10(23C)(iiiab) of the Act and thereby disallowed the exemption under Section 10(23C)(iiiab) of the Act in reassessment proceedings on the ground that it is not wholly and substantively financed by the Government. The CIT(A) also confirmed the order of the AO and held that the reopening made by the AO is valid. On appeal the Tribunal held that the AO has duly examined and scrutinized the details submitted during the course of assessment proceedings and has applied his mind regarding exemption under Section 10(23C)(iiiab) of the Act. Therefore, there was no new tangible material which had come into possession of the AO to form belief that by reason of non-disclosure truly and fully all material facts, necessary for assessment, the income chargeable to tac has escaped assessment. Relying on various judicial precedents held that reopening of assessment on the basis of Revenue Audit Objection does not constitute an information for the purpose of reopening of assessment. Further, the Tribunal also held that reopening on the same material amounts to mere change of opinion which is not permissible under the law relying on various judicial precedents. It is well settled that the power under Section 147 of the Act is not a power of review but a power to reassess, thus permitting reopening of assessment on a change of opinion as to the taxability of the income of the assessee is outside the scope of Section 147 of the Act.  (AY. 2010-11)