Sec. 147 & 148 of Income Tax Act, 1961—Reassessment — Opinion of an internal audit party of the Income Tax Department on a point of law cannot be regarded as "information" within the meaning of section 147(b) of the Income Tax Act, 1961”. Thus, this Court being fully satisfied that the impugned reopening of the assessment is contrary to law. The question of directing the assessee to avail alternate remedy of appeal before the Commissioner of Income Tax does not arise, especially when the case is one of change of opinion. Section 147 would not give arbitrary powers to the assessing officer to reopen assessments on the basis of mere change of opinion, which cannot be per se reason to reopen. It was further pointed out that there is a conceptual difference between power to review and power to reassess. The assessing officer has no power to review; he has power to reassess and such reassessment is to be based on certain pre-conditions. Further, the assessing officer has power to reopen, provided there is tangible material to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation of the belief  — MOBIS INDIA LIMITED Vs. DEPUTY CIT  [2020] 421 ITR 463 (MAD)