Change of Opinion Bar

This ruling reinforces that reassessment cannot be used as a backdoor to revisit settled issues. Where a claim, such as deduction under Section 80-IB(10), has already been examined and allowed in earlier proceedings, the Revenue cannot reopen a subsequent year merely by relying on its earlier disallowance.

The Supreme Court’s refusal to interfere cements the principle that reassessment must be based on fresh tangible material, not recycled reasoning.