Sec. 147 of Income Tax Act, 1961—Reassessment— No tangible material is shown on the basis of which the assessment is sought to be reopened and in the absence of tangible material, what the AO has done while reopening the assessment is only to change the opinion which was formed earlier on the allowability of the deduction and power to reopen an assessment is conditional on the formation of a reason to believe that income chargeable to tax has escaped assessment and power is not akin to a review - The existence of tangible material is necessary to ensure against an arbitrary exercise of power and there is no tangible material in the case of assessee. - MEDLEY PHARMACEUTICALS LTD. V/s DEPUTY CIT - [2020] 207 TTJ 143 (ITAT-MUMBAI)