Reopening on later property valuation valid where statutory assessment supplied relevant information showing possible undervaluation.

Reopening of gift-tax assessment under section 16(1)(b) was held to be valid where the assessing authority acted on a Wealth-tax Officer's statutory valuation of the same gifted property at a higher figure for the same assessment year. That valuation constituted relevant "information" because it supplied concrete factual material, not a mere change of opinion, and had a rational nexus with a belief of possible undervaluation. The time gap between the gift date and the wealth-tax valuation did not break the connection, as no intervening change in the property's value was shown. The reopening was therefore upheld as lawful and not vitiated by change of opinion.

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Issues: Whether reopening of gift-tax assessment under section 16(1)(b) of the Gift-tax Act, 1958 was valid on the basis of information received from the Wealth-tax Officer regarding the higher valuation of the same gifted property in the donee's assessment.

Analysis: The basis of reopening was not a mere valuation report or a mere change of opinion, but the statutory order passed by the Wealth-tax Officer valuing the same property at a higher figure for the same assessment year. Such information related to an existing factual position about the very property earlier assessed, and therefore satisfied the settled tests of "information" for reopening: it conveyed factual particulars, had concrete relevance, and possessed definitive vitality for forming the required belief. The time gap between the gift date and the wealth-tax valuation date did not break the nexus, because the property was the same, the assessment year was the same, and no material showed any intervening alteration in value. The reopening was therefore based on relevant material having a rational connection with the belief of undervaluation.

Conclusion: The reopening was valid in law and was not vitiated by change of opinion; the answer to the referred question was against the assessee and in favour of the Revenue.

Final Conclusion: Information arising from a subsequent statutory assessment of the same property can justify reopening where it constitutes relevant factual material showing possible undervaluation and is not merely an opinion on law.

Ratio Decidendi: An order of a competent taxing authority determining the value of the same property for the same assessment year may constitute "information" for reopening, provided it furnishes relevant factual material bearing a rational nexus to the belief of escapement or undervaluation.

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