Valuation Officer report as "information" supports reassessment notices; writ interference refused for lack of jurisdictional error.

A statutory Valuation Officer's report under the Wealth-tax Act can constitute "information" for reopening purposes when it provides new factual material not previously before the assessing authority. The Court held that such a report is not excluded merely because it contains expert opinion, since valuation is not an exact science and the statutory meaning of information includes external factual material. Concerns about repeated reopening could not narrow that meaning, and authorities on mere change of opinion were held inapplicable. The reassessment notices were therefore validly issued, and no jurisdictional or manifest legal error justified writ interference under Article 226.

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Issues: Whether a Valuation Officer's report obtained under the Wealth-tax Act could constitute "information" within the meaning of the reopening provision so as to justify reassessment notices, and whether such notices were liable to be interfered with in writ jurisdiction.

Analysis: The report of a statutory Valuation Officer under section 16A is not to be treated as a mere internal opinion lacking factual character. The Court applied the settled meaning of "information" drawn from the analogous reopening provisions in the earlier income-tax enactments and the present income-tax law, and held that information may include factual material obtained from an external source. A valuation report, even though it embodies expert opinion, is still information as to a fact because valuation is not an exact science and the report supplies new material not previously before the assessing authority. The Court further held that the apprehension of endless reopening cannot narrow the statutory meaning of "information", and that the cited authorities on mere change of opinion did not govern the present situation.

Conclusion: The reassessment notices were validly issued on the basis of the Valuation Officer's report, and no jurisdictional or manifest legal error was shown to warrant interference under Article 226 of the Constitution of India.

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