Reassessment notice invalid where reopening merely corrected earlier assessment errors without fresh information.

A reassessment notice under section 148 read with section 147(b) of the Income-tax Act was held invalid because it was not based on fresh information. The record showed that the Income-tax Officer was attempting to correct earlier mistakes in the original assessment, including depreciation, repairs and closing stock treatment, rather than reopening on a statutory basis. As the alleged grounds reflected only a change of opinion or matters fit for rectification, the precondition for reassessment under section 147(b) was not satisfied. The notice was therefore quashed.

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Issues: Whether the reassessment notice issued under section 148 read with section 147(b) of the Income-tax Act, 1961 was valid in the absence of fresh information and when the attempted reopening appeared to be only a rectification of the officer's own earlier mistakes.

Analysis: The notice was found to rest on no real information justifying reopening. The materials showed that the Income-tax Officer was seeking to correct mistakes already committed in the original assessment, including allowance of higher depreciation and computation of repairs, and the matter of closing stock reflected only a change of opinion. Such errors, if at all, were matters for rectification rather than reassessment, and the record did not support the statutory precondition for action under section 147(b) read with section 148.

Conclusion: The reassessment notice was invalid and liable to be quashed.

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