(A) Income Tax - Reopening of assessment - Material available for reopening - Not a case of mere change of opinion - Acceptance of assessee's case in original assessment does not preclude reopening of assessment for an earlier year based on findings of fact made on the basis of fresh materials in the course of assessment of the next assessment year.

Facts of the case:
An assessment for an earlier year was reopened by the tax authorities based on fresh materials and findings of fact discovered during the assessment of a subsequent year. The assessee challenged this reopening on the ground that their case had been accepted as correct in the original assessment for that specific assessment year.

Findings of Court:
The court found that there was sufficient material on the basis of which the officer could proceed to reopen the case and that the action did not constitute a mere change of opinion.

Issues: Whether the tax authorities are precluded from reopening an assessment of an earlier year if the assessee's case was accepted in the original assessment, provided fresh materials are found during a subsequent year's assessment.

Ratio Decidendi: The acceptance of an assessee's case in the original assessment does not prevent the reopening of that assessment if the officer discovers fresh materials during the assessment of a later year that justify such a reopening, provided the proceeding is based on material and not a mere change of opinion.

Result: Appeal dismissed.