Reopening of assessment requires definite new information linked to escaped income, not a later change in view on related facts.

Section 34 of the Income-tax Act, 1922 permits reopening only when the Income-tax Officer receives definite information that directly leads to the discovery of escaped income. Where the assessee had already disclosed the commission receipt in the original return and the officer knew its amount, a later excess profits tax finding about the payer's expenditure under Rule 12 of Schedule I did not provide the necessary causal nexus. That later view concerned a different question and did not reveal any undisclosed income of the assessee. Reopening was therefore not valid.

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Issues: Whether the Income-tax Officer was entitled to reopen the assessee's assessment under Section 34 of the Income-tax Act, 1922 on the basis of information arising from the excess profits tax proceedings.

Analysis: The assessee had disclosed the commission received in the original return, and the Income-tax Officer was already aware of the receipt and its amount. The later excess profits tax finding concerned only the allowability of the payer's expenditure under Rule 12 of Schedule I to the Excess Profits Tax Act, which was a distinct question and had no bearing on the assessee's taxable receipt. For Section 34 to apply, the Income-tax Officer must receive definite information that leads to the discovery that income has escaped assessment, and there must be a causal nexus between the information and the discovery. A mere later view that the same facts justify a different allowance for another assessee does not amount to such discovery.

Conclusion: The reopening under Section 34 was not valid, and the answer to the referred question was in the negative.

Ratio Decidendi: Section 34 can be invoked only when definite information newly leads to the discovery of escapement of income, and a mere change of opinion or irrelevant information unconnected with that discovery cannot justify reopening.

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