Reopening of gift-tax assessment failed where unsupported opinion was not valid information under section 16(1)(b).

Reassessment under section 16(1)(b) requires post-assessment information from an external source that gives precise and authentic knowledge of escaped taxable gift; a mere change of opinion is insufficient. The revenue's letter contained only a general, unsupported assertion about land value and no specific factual material relating to the alleged escaped gift, so it did not qualify as information. The condition precedent for reopening was therefore not satisfied and the notice was invalid.

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Issues: Whether the notice reopening the gift-tax assessment was validly issued under section 16(1)(b) on the basis of the material said to constitute information.

Analysis: Section 16(1)(b) permits reassessment only where the Gift-tax Officer has, in consequence of information in his possession, reason to believe that taxable gift has escaped assessment. The provision requires post-assessment information from an external source that is capable of giving precise and authentic knowledge about the escaped gift; a mere change of opinion does not suffice. The letter relied upon by the revenue contained only a general assertion that land in the locality could not be of no value, without supporting data or specific factual material relating to the escaped gift. Such a bald opinion, especially when it merely contradicted the approved valuer's view, did not amount to the kind of information contemplated by the provision.

Conclusion: The condition precedent for reopening under section 16(1)(b) was not satisfied and the notice was invalid.

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