Reassessment on later valuation report as "information" under section 147(b); non-speaking SLP dismissal creates no binding precedent.

A subsequent departmental valuation report can qualify as "information" under section 147(b) of the Income-tax Act, 1961 where it supplies a new external fact relating to assessment after the original assessment has been completed. The text also states that a non-speaking dismissal of a special leave petition does not amount to affirmation of the underlying Bombay decision or create binding precedent under article 141. In that setting, reassessment notices issued on the basis of the later valuation report were treated as valid, and writ interference at the notice stage was considered inappropriate because the assessee could still contest the valuation in reassessment proceedings.

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Issues: Whether a subsequent report of the departmental valuation officer constituted "information" within the meaning of section 147(b) of the Income-tax Act, 1961 so as to justify reopening of the concluded assessment; and whether the writ court should interfere with the reassessment notices at the threshold.

Analysis: The expression "information" in section 147(b) is wide enough to include knowledge derived from an external source concerning facts bearing on assessment. A subsequent valuation report is a fact in itself, and its later availability may furnish information for reopening, provided the assessment had already been completed on the earlier materials. The earlier dismissal of a special leave petition against a Bombay decision did not amount to affirmation of that decision or the laying down of any binding principle under article 141, especially when the Supreme Court order was non-speaking. The impugned notices did not finally determine the petitioner's rights, and the assessee could still contest the valuation in the reassessment proceedings. In these circumstances, there was no jurisdictional error or manifest error of law warranting interference under article 226 at this stage.

Conclusion: The subsequent valuation report did constitute information for the purpose of section 147(b), and the reassessment notices were validly issued. The writ petitions were not maintainable for interference at the notice stage.

Ratio Decidendi: A subsequent departmental valuation report, being a new external fact relating to assessment, can constitute "information" enabling reopening of a concluded assessment under section 147(b) of the Income-tax Act, 1961; a non-speaking dismissal of an SLP does not create binding precedent.

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