Reassessment requires definite new information; mere change of opinion or fresh scrutiny of existing records cannot justify reopening.

Reassessment under Section 34 of the Indian Income-tax Act was permissible only if the Income-tax Officer possessed definite new information and, because of that information, discovered escaped or under-assessed income. Mere suspicion, a fresh look at the same record, or a change of opinion by a successor officer did not satisfy the statutory condition. On the record, no definite new information had come into possession before reassessment was initiated, and the action was based only on reinvestigation of the earlier assessment material. The reopening was therefore invalid, and the Income-tax Officer was not entitled to proceed under Section 34.

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Issues: Whether the Income-tax Officer was entitled to reopen the assessment under Section 34 of the Indian Income-tax Act on the basis of definite information resulting in discovery of under-assessment.

Analysis: Section 34 required the existence of definite information in the possession of the Income-tax Officer, discovery of escaped or under-assessed income, and a causal connection between that information and the discovery. Mere suspicion, a fresh examination of the same material, or a change of opinion by a successor officer did not satisfy the statutory condition. On the record, no definite new information was shown to have come into possession of the Income-tax Officer before the reassessment proceedings were initiated, and the reopening appeared to be based only on reinvestigation of the earlier assessment material.

Conclusion: The reopening was not valid and the Income-tax Officer was not entitled to proceed under Section 34.

Ratio Decidendi: Reassessment under Section 34 can be sustained only when escaped income is discovered in consequence of definite new information; a mere change of opinion or fresh scrutiny of existing material is insufficient.

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