Reassessment without definite factual material is invalid when based only on a later administrative opinion on tax rate.

Reassessment notices were held invalid because the Assessing Authority lacked definite factual information showing under-assessment of the petitioner's turnover. A Commissioner's letter merely expressed the view that rice bran oil was inedible and should be taxed at a higher rate; it did not disclose suppression, concealment, or any material that came to notice after the original assessments. The letter was prospective in nature and could not reopen concluded assessments. In the absence of material capable of supporting a belief of under-assessment, the statutory basis for reassessment was not satisfied, and the notices were without jurisdiction.

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Issues: Whether the reassessment notices could be sustained when the Assessing Authority lacked definite information showing under-assessment of the petitioner's turnover.

Analysis: The notices were issued after the Commissioner's letter, which expressed only an opinion that rice bran oil was inedible and should be taxed at a higher rate. The letter did not supply any factual material relating to suppression or concealment by the petitioner, nor did it disclose material that had come to the Assessing Authority's notice after the original assessments. The instructions in the letter were prospective and did not direct reopening of concluded assessments. In the absence of definite information capable of founding a belief of under-assessment, the statutory precondition for reassessment was not met.

Conclusion: The reassessment notices were without jurisdiction and invalid.

Ratio Decidendi: Reassessment can be initiated only on the basis of definite factual information indicating under-assessment; a later administrative opinion or prospective instruction, without such material, does not confer jurisdiction to reopen concluded assessments.

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