Sec. 147 of Income tax Act, 1961 — Reassessment—It is well settled that no reassessment/reopening can be undertaken on the basis of mere audit objections/query raised by the internal auditors of the Department — Assessing Officer had no "reason to believe" any escapement of income to assessment but is a clear case of change of opinion, hence, assumption of jurisdiction by the Assessing Officer to invoke section 147 cannot be sustained and this aspect of "change of opinion" would be suffice to quash the impugned notice without going into the merits of the other arguments advanced by the learned counsel for the petitioner. The issuance of the second notice under section 148 to reassess the income of the assessee on the premise that the Assessing Officer has reason to believe that the income chargeable to tax has escaped assessment within the meaning of section 147 is based on the same reasons recorded for the first notice issued under section 148 and no final orders have been passed on the same and he notice impugned does not show the availability of the tangible material to believe the escapement of income from assessment and no new material was available before the Assessing Officer to reissue the second notice, thus, reopening of assessment invalid — Hemamalini Maiya (P.) vs. Asstt. CIT [2020] 421 ITR 79 (KARN)