Reassessment on later-realised information from the record remains valid; mere change of opinion does not bar reopening.

Reassessment under Section 147(b) is justified where the Income-tax Officer has reason to believe income escaped assessment on the basis of information in possession, including material already on record whose significance is later realised. Such information may emerge from further enquiry or legal analysis, and a mere change of opinion does not invalidate reopening if the action is founded on information rather than a different line of reasoning alone. On that basis, reopening remains valid when the escaped income belief is derived from the record and subsequent appreciation of its implications.

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Issues: Whether reopening of the assessment under Section 147(b) of the Income-tax Act, 1961 was valid on the basis of information available from the record and the subsequent realization of its implications.

Analysis: Reopening under Section 147(b) is justified when the Income-tax Officer has reason to believe that income has escaped assessment in consequence of information in his possession. Such information may be derived from the record itself or from further enquiry or research into the facts or law, even if it could have been obtained earlier. A mere change of opinion does not invalidate reassessment where the reassessment is founded on information and not on a different method of reasoning alone.

Conclusion: The reopening of the assessment under Section 147(b) was valid.

Ratio Decidendi: Information for the purpose of reassessment may arise from material already on record when its significance is later realised, and reassessment is valid if founded on such information leading to a reason to believe that income has escaped assessment.

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