Reopening of completed assessment requires fresh information; an internal audit note or change of opinion cannot justify reassessment.

Reopening of a completed assessment under section 8(b) of the Companies (Profits) Surtax Act, 1964 is valid only where the assessing officer possesses subsequent information that objectively gives rise to a reason to believe that chargeable profits escaped assessment. The materials relied on here were vague and indefinite, disclosed no fresh factual or legal basis, and did not identify any specific omission or error; an internal audit note by itself was insufficient. The attempted reassessment was therefore treated as a mere reappraisal of the same material and a change of opinion, so the reopening failed.

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Issues: Whether the reopening of the completed assessment under section 8(b) of the Companies (Profits) Surtax Act, 1964 was valid, in particular whether the Income-tax Officer had information in his possession giving rise to reason to believe that chargeable profits had escaped assessment.

Analysis: Section 8(b) is an enabling provision analogous to section 147(b) of the Income-tax Act, 1961 and section 34(1)(b) of the Indian Income-tax Act, 1922. Reopening is permissible only when subsequent information comes into the possession of the Income-tax Officer and that information is the basis for the formation of the statutory belief. The materials relied on in this case were found to be vague and indefinite, did not pinpoint any specific error or omission, and did not disclose any fresh factual or legal material. A note by an internal audit party, without more, was held not to constitute the required information. The attempted reopening was therefore traced only to a reappraisal of the same material and a change of opinion.

Conclusion: The reopening was invalid, as the Income-tax Officer had no relevant information in his possession and the reassessment was based only on a change of opinion, not on material satisfying section 8(b).

Ratio Decidendi: Reassessment under the escapement provision can be sustained only if the assessing authority possesses subsequent information that objectively justifies the statutory belief of escapement; a mere internal audit note or a rethinking of the original assessment on the same material is insufficient.

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