Reassessment requires fresh definite information; later clarification of disclosed facts cannot justify reopening a completed assessment.

Fresh definite information is required to reopen a completed assessment under Section 34 of the Income-tax Act, 1922; a later reply that merely quantifies facts already disclosed does not satisfy that standard. The assessees had already disclosed their interest in the Ahmedabad firm, and the Income-tax Officer had set the enquiry in motion on that basis before completing the assessment. The subsequent figures from Ahmedabad only supplied the precise amount and did not amount to new information justifying reassessment. A notice issued on that material was therefore not warranted, and the matter was decided in favour of the assessees.

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Issues: Whether the reply received from the Income-tax Officer, Ahmedabad, constituted definite information so as to justify action under Section 34 of the Income-tax Act, 1922.

Analysis: The assessees had already disclosed in their return that they held an interest in the Ahmedabad firm. The Income-tax Officer had therefore set the relevant enquiry in motion on the basis of facts already disclosed and completed the assessment without waiting for the reply. The later figures received from Ahmedabad merely supplied the precise amount in response to an enquiry already initiated and did not amount to fresh or definite information of the kind required to reopen a completed assessment under Section 34. The statutory power could not be used to revise an assessment merely because the officer later realised that he had omitted a disclosed item.

Conclusion: The reply from Ahmedabad was not definite information within the meaning of Section 34, and the notice issued thereunder was not justified; the answer was in favour of the assessees.

Ratio Decidendi: For reopening a completed assessment under Section 34 of the Income-tax Act, 1922, the Income-tax Officer must receive fresh definite information leading to the discovery of escaped income, and not merely a later clarification of facts already disclosed or an omission caused by his own incomplete assessment.

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