Change of opinion is not "information" for reassessment when authorities rely on the same materials already on record.

Reassessment under section 18(1) of the Bihar Sales Tax Act, 1959 cannot be initiated on the same materials already examined in the original assessment, because a mere second thought or change of opinion does not amount to "information" for reassessment. Where the deduction claim was accepted after scrutiny of the record and accounts, a later notice based on the same facts is impermissible. The reassessment initiation was therefore invalid.

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Issues: Whether reassessment under section 18(1) of the Bihar Sales Tax Act, 1959 could be initiated on the same materials already considered in the original assessment, and whether such a mere change of opinion could amount to "information" for reassessment.

Analysis: The original assessment had accepted the deduction claim after examination of the record and verification of accounts. The reassessment notice was issued after a long lapse of time on the very same materials already before the assessing authority. The governing principle, as previously laid down, is that "information" for reassessment under section 18(1) need not always come from an external source, but a mere second thought or change of opinion on the same facts and materials does not constitute information for that purpose.

Conclusion: Reassessment on the same materials was impermissible and the initiation of reassessment was invalid.

Ratio Decidendi: A reassessment under section 18(1) cannot be founded merely on a change of opinion about the same set of facts and materials already on record, because such change does not amount to "information" within the meaning of the provision.

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