Reassessment based on audit objection requires the assessing authority's own satisfaction; external direction alone is insufficient.

Section 19 of the Bihar Finance Act, 1981 permits reassessment only when the prescribed authority, on the basis of information in its possession, forms its own satisfaction that turnover has escaped assessment. An audit objection may qualify as information only if it identifies an overlooked factual matter already reflected in the record, but reopening cannot rest on a mere change of opinion or external direction. The SC noted that the assessing authority was not independently satisfied and acted on the audit party's direction despite its own view on taxability. The reassessment was therefore held to be without jurisdiction.

---

---

Issues: Whether an audit objection could constitute information for reopening assessment under Section 19 of the Bihar Finance Act, 1981, and whether the assessing authority had the requisite satisfaction that turnover had escaped assessment.

Analysis: Section 19 permits reassessment only when, upon information in the possession of the prescribed authority, it is satisfied that there are reasonable grounds to believe that turnover has escaped assessment. An audit objection may amount to information where it points out a factual omission or an overlooked matter already reflected in the record, but reopening cannot rest on a mere change of opinion. On the materials considered, the assessing authority was not independently satisfied that turnover had escaped assessment; rather, the reassessment was initiated on the audit party's direction despite the authority's own view that the goods had been consumed and did not attract tax in the manner proposed by audit.

Conclusion: The reassessment was without jurisdiction because the statutory condition of the assessing authority's own satisfaction on the basis of information was not met.

Ratio Decidendi: Reassessment under the escaped-assessment provision is valid only where the prescribed authority, on the basis of information, forms its own satisfaction that turnover has escaped assessment; an audit objection can be information only if it reveals an overlooked factual matter, and not where the reopening is founded merely on external direction or a change of opinion.

---