The same view was taken in a later case by the Nagpur High Court in Income tax Appellate Tribunal Bombay vs B. P. Byramji & Co.(1) where it was again emphasised that a mere change of opinion by the Income tax Officer is no ground for taking action under section 34, Further in Bhimraj Pannalal vs Commissioner of Income tax Bihar(1) it was held by the Patna High Court that "an order of assessment made after investigation by a particular officer should Jr not at his sweet will and pleasure be allowed to be revised merely because he changed his opinion and that there must exist something either suppressed by the assessee or a fact or a point of law which was inadvertently or otherwise omitted to be considered by the Income tax Officer, before he can proceed to act under section 34; and a mere change of opinion on the same facts and law is not covered by that section." (1) [1959] supp.