The AO reopened assessment after four years on the issue of guarantee fee, even though the same issue was already pending in appeal before the Tribunal. The reasons recorded did not allege any failure by the assessee to disclose fully and truly all material facts; rather, they were based on information already available in the return and computation of income during the original assessment. The Court observed that reasons furnished to the assessee at the first instance alone must be considered, and the AO cannot supplement fresh reasons through an affidavit. Further, no new tangible material was cited, and reopening was therefore held to be a mere change of opinion. Additionally, as per the third proviso to s. 147, reassessment cannot be initiated on an issue already pending before an appellate authority. Thus, both for want of fresh material and in view of the statutory bar, the reassessment notice and order were quashed. (AY. 2014-15)