Reassessment on audit objection and later legal interpretation cannot reopen a concluded assessment after finality has attached.

A concluded assessment could not be reopened under the reassessment provision merely because of an audit objection and a later change in legal interpretation. The court treated an audit note as not amounting to definite information for reopening under section 11A of the Punjab General Sales Tax Act, 1948, and held that a subsequent interpretative view could not by itself justify reassessment after finality had attached. Reopening on such a basis would permit repeated reassessment whenever the legal view changed. The reassessment was therefore invalid and the reassessment order was set aside in favour of the assessee.

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Issues: Whether reassessment could be sustained when it was initiated on the basis of an audit objection and a later interpretation of law after the original assessment had attained finality.

Analysis: The assessment for the relevant year had already attained finality, and the reopening was founded only on an audit objection and a later legal view. Such an audit note was not treated as "definite information" for the purpose of reassessment under section 11A of the Punjab General Sales Tax Act, 1948. A subsequent change in interpretation after the original assessment could not justify reopening the concluded assessment, since that would permit repeated reassessment every time a new view was taken on the law. The reasoning followed the principle that an audit opinion or later change of legal interpretation does not, by itself, constitute the statutory basis for reassessment.

Conclusion: Reassessment was not validly initiated on the basis of the audit objection or subsequent change in interpretation, and the reassessment order was set aside in favour of the assessee.

Ratio Decidendi: An audit objection and a later change in legal interpretation do not constitute definite information for reopening a concluded assessment under the reassessment provision.

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