Fresh information is mandatory for reassessment; mere change of opinion cannot justify reopening under section 11-A.

Section 11-A reassessment required fresh information received after the original assessment, followed by satisfaction based on that information and notice to the dealer; a mere change of opinion on the same material was insufficient. The dealer could challenge whether the alleged information existed and was relevant, and the authority's failure to disclose the date or nature of that information showed the jurisdictional condition was not met. Revision powers under sections 22-A and 22-B were treated as distinct and not a basis for reopening under section 11-A, so the reassessment proceedings were without jurisdiction and the notice was quashed.

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Issues: Whether proceedings for reassessment under section 11-A of the Central Provinces and Berar Sales Tax Act, 1947 could be validly initiated without disclosure or proof of fresh information coming into the taxing authority's possession after the original assessment.

Analysis: Section 11-A was construed to require three objective conditions before reassessment could be undertaken: receipt of information, satisfaction founded upon that information, and notice to the dealer. The expression "in consequence of any information which has come into his possession" was held to mean information received subsequent to the original assessment. A mere change of opinion on the same material was insufficient. The dealer's right to be heard implied a right to question the existence and relevance of the alleged information, and the authority's inability to disclose the date or nature of the information was treated as showing absence of the jurisdictional prerequisite. The provisions for revision under sections 22-A and 22-B were distinguished as different in nature and not a basis for reopening under section 11-A.

Conclusion: Proceedings under section 11-A were without jurisdiction because no fresh information justifying reassessment was shown.

Final Conclusion: The notice for reassessment was quashed and prohibition issued against further action under section 11-A.

Ratio Decidendi: Reassessment under a provision conditioned on "information" can be initiated only when the authority acts on fresh information received after the original assessment, and the existence of that jurisdictional fact is open to judicial scrutiny.

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