Reassessment based on a binding statutory decision is valid information, not a mere change of opinion.

A mere change of opinion by the assessing authority does not, by itself, justify reassessment. Where reassessment is reopened after a later binding decision of a competent statutory authority under the taxing statute, the reopening is based on information rather than on a change of opinion. The authority is entitled to act on the legal position declared by the binding decision, and such a reopening is treated as valid under the Act.

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Issues: Whether reassessment could be reopened on the basis of a later binding decision of the Tribunal or other superior authority, or whether such reopening amounted merely to a change of opinion.

Analysis: A mere change of opinion by the assessing authority cannot by itself justify reopening of an assessment. However, where the assessing authority reopens the assessment after a decision of a binding statutory authority under the Act, the action is not treated as a mere change of opinion. Such a decision is to be regarded as information for the purpose of reopening, because the assessing authority is entitled to act on the legal position declared by the competent authority whose orders bind it.

Conclusion: The reopening of the assessment was valid and the challenge based on mere change of opinion failed.

Ratio Decidendi: Reopening of an assessment based on a binding decision of a competent authority under the taxing statute is founded on information and not on a mere change of opinion.

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