The Madras High Court held that the reassessment proceedings initiated under section 147 were invalid as they were based merely on a change of opinion and not on any fresh tangible material. The assessee had fully and truly disclosed all primary facts relating to interest paid and utilisation of borrowed funds during the original assessment proceedings, and the Assessing Officer, after raising queries and examining the details, had completed the assessment under section 143(3). The Court observed that once relevant particulars are disclosed and considered, the Assessing Officer cannot reopen the assessment simply because he subsequently forms a different view on the same material. It was further held that the assessor’s duty does not extend to disclosing inferences and reopening on the same issue amounts to impermissible review of the original assessment. Accordingly, the reopening was quashed and decided in favour of the assessee.(AY.2006-07)