The income tax officer is not permitted to review his own order so do his successor in office. If he does so than it is popularly called as change of opinion.
A reassessment which is reasoned by change of opinion is therefore impermissible under the income tax law.
The Bombay High Court while dwelling on this subject held that when on consideration of material fact one view was exclusively taken by the AO than it would not be open to reopen the assessment based on the very same material with a view to take another view.
In this case the new AO turned in who held a view that other service charges/common maintenance charges were inseparably connected to the letting out of the building of the assessee so that it wanted them to be charged under the head house property which the Court termed it as mere change of opinion.
This principle is sacrosanct and more rigorous under the new scheme as the AO now while initiating enquiry u/s 148A is expected to announce the text/source and date of receipt of information and material as basis of reopening