Reassessment under section 147(b) and the scope of "information" raised questions of general importance for appeal certification.

The commentary addresses whether questions on reassessment under section 147(b) of the Income-tax Act, 1961, raised issues of general importance suitable for certification to appeal to the Supreme Court. It notes the legal question whether a High Court decision later reversed by the Supreme Court could constitute "information" for reopening an assessment, and whether reassessment could extend to escapement unrelated to the information relied on for reopening. As the High Court decisions on these points were not uniform, the court treated the questions as of general importance and directed that a certificate to appeal be issued.

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Issues: Whether the case was fit for a certificate to appeal to the Supreme Court on questions of general importance arising from the scope of reassessment under section 147(b) of the Income-tax Act, 1961.

Analysis: The questions framed involved the legal effect of a High Court decision later reversed by the Supreme Court as "information" for reopening assessment, and whether reassessment under section 147(b) could extend to escapement unrelated to the information on which the reopening was based. The Court found that the relevant decisions of different High Courts on these questions were not uniform and that the questions were of general importance.

Conclusion: The case was held to be a fit one for a certificate to appeal to the Supreme Court, and the certificate was directed to be issued.

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