After receiving the Section 148 notice, the Petitioner filed its return and requested the reasons recorded for reopening on 20.04.2021. Accordingly, reopening after more than four years was contended to be a case of change of opinion. The Court held that there was no fresh or new tangible material available with the Revenue for reopening the assessment. In the present case, the reasons were based on material already available in the assessment records and did not disclose any fresh tangible material. In other words, there was no fresh or new tangible material available with the revenue to reopen the assessment.