T. V. K. NATATAJA CHANDRAN, A.M These appeals by assessee are consolidated and disposed of by common order for sake of convenience as issue is common and arise from consolidated order of AAC of IT dt. 1st July, 1983. relevant facts in brief are that assessee is individual and derives income from business in silver wares and gold jewellery. assessment for asst. yrs. 1977-78 and 1978-79 were originally completed by ITO under s. 143(1) of IT Act, 1961. assessments were originally completed by ITO under s. 147(b) for reasons that assessee has not valued closing stock of silver wares and gold jewelleries at weighted average rate as was done in earlier years and thereby income had escaped assessment. According to ITO he informed himself about this position at time of assessment proceedings for asst. yr. 1979-80, when particulars were furnished by assessee. Accordingly he determined under valuation o f closing stock at Rs. 35,586 and Rs. 9,074 respectively for these years and added amounts as income for these years. On appeal, AAC concurred with view of ITO as according to him assessee valued on ad hoc method without taking into account making charge which would go into cost of silver and gold jewellery kept in stock. Consequently, he confirmed addition made by ITO for these years. ld. counsel for assessee firstly contended that ITO had no jurisdiction to reopen assessment under s. 147(b) and, therefore, AC ought to have cancelled reassessments on that score. ITO had no material so as to constitute fresh information and addition made in closing stock was as result of mere change of opinion. Secondly, he contended that assessee has been systematically following particular method of accounting for valuing closing stock and ITO ought not to have disturbed such valuation. Thirdly he vehemently contended that ITO was not correct in his statement that assessee had been following method of weighted average rate in earlier years for purpose of valuing closing stock. Consequently, he urged that orders of authorities should be set aside. ld. departmental representative on other hand supported orders of authorities on ground that information for reopening assessment came into position of ITO during course of assessment proceedings for asst. yr. 1979-80 and, therefore, reassessments made were valid in law. Even on merits he supported orders of authorities and urged that additions made should be sustained. We have duly considered rival contentions and facts of case. At outset, we have to observe that contentions raised by ld. counsel for assessee are quite valid and forceful. ITO has originally accepted income returned by assessee as complete and correct under s. 143(1) of IT Act, 1961. He has not given any material or basis to come to conclusion that assessee has deviated from method of valuing closing stock on weighted average basis. On other hand, this statement of ITO was found to be wrong as vehemently contended by ld. counsel for assessee. According to assessee, he has been valuing closing stock on basis of "last in first out method". assessments cannot be reopened simply to find out correct method of valuation to be adopted for valuing closing stock after assessments were completed. cost of making charges will, no doubt, go to increase cost of production of manufacture, but as long as they are embedded in jewellery and remain in stock increase in value is only notional and not real so as to constitute information for purpose of taxation. Only when sales are effected commercial profits arises therefrom, and it is well accepted maxim that no one makes profits out of himself. When once silver wares were manufactured and remained in stock and carried forward from year to year market value of such unsold stock may be even less than cost of production for want of demand of particular make to type of ornaments. Any adjustment in valuing of closing stock of one year is duly offset by enhancement of opening stock in next year. In past it has been stated before us that assessee has been adopting same method of valuation of closing stock consistently and it was accepted by Department. Therefore, very basis for entertaining reasons that income had escaped assessment for these years on ground that assessee did not value closing stock for these years on ground that assessee did not value closing stock of silver wares at weighted average rate on wrong notion of assessee having followed such method was not factually correct and, therefore, reassessments taken were not valid in law and justified by facts and circumstances of case. It is only case of change of opinion and there is no material information warranting reopening of assessments. Therefore, we have no hesitation in setting aside orders of AAC and that of ITO as reassessments were not justified in law and in facts and circumstances of case. In result, appeals are allowed. *** S. RAJAGOPAL CHETTIAR v. INCOME TAX OFFICER