No reassessment to tax profit on land dealings as business income and not as capital gains on whims

IT: Where in course of assessment, Assessing Officer accepted assessee's claim that income arising from sale of land was taxable as 'long-term capital gain', in absence of any new material brought on record, Assessing Officer could not initiate reassessment proceedings on basis of mere change of opinion that income in question was taxable as 'business income'