Reassessment jurisdiction cannot rest on a later realisation of error from the same material already considered; no referable question arose.

An assessment cannot be reopened under the reassessment provision merely because the Assessing Officer later realises that the original assessment involved an error on the same material already considered; a self-discovered mistake is not "information" for jurisdictional reopening. Applying binding Supreme Court authority on the meaning of information, the HC held that a fresh look at existing material did not satisfy the statutory condition for reopening. Because the point was already settled by precedent, no referable question of law arose for a statement of the case, and no direction to refer the proposed question could be issued.

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Issues: Whether the Assessing Officer could reopen the assessment under section 147(b) on the basis of his later realisation that the original assessment contained an error in applying the circular, and whether that controversy raised a referable question of law under section 256(2).

Analysis: The earlier Supreme Court authority on the scope of "information" under the reopening provision was applied. A reassessment cannot be founded merely on a fresh look at the same material or on the Assessing Officer's discovery of his own earlier mistake. Since the original reopening was based only on a reconsideration of the same materials and not on subsequent external information, the jurisdictional condition for reopening was not satisfied. As the point was already concluded by binding precedent, no referable question of law arose for a statement of the case.

Conclusion: The challenge to reopening failed, and no direction could be issued to refer the proposed question of law.

Ratio Decidendi: An assessment cannot be reopened under the reassessment provision merely because the Assessing Officer later realises that the original assessment involved an error on the same material already considered; such a self-discovered error is not "information" conferring jurisdiction to reopen.

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