Fresh information required for estate duty reassessment; mere opinion on valuation cannot reopen completed proceedings.

Section 59(b) of the Estate Duty Act, 1953 permits reassessment only when the Controller receives fresh information that leads to a reasonable belief that estate duty has escaped assessment. A mere reappraisal of the same valuation material, or an appellate authority's unimplemented opinion on that valuation, does not supply new information. The Court distinguished between genuinely new facts and a change of view on existing facts, holding that the latter cannot justify reopening completed proceedings. A mere expression of opinion by the Central Board of Revenue therefore does not constitute information within section 59(b).

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Issues: Whether a mere expression of opinion by the appellate authority on the valuation adopted in the original assessment constitutes "information" within section 59(b) of the Estate Duty Act, 1953, so as to justify reassessment.

Analysis: Section 59(b) permits reassessment only when the Controller has, in consequence of information in his possession, reason to believe that property chargeable to estate duty has escaped assessment. The Court distinguished between fresh information and a mere reappraisal of the same material already considered in the original and appellate assessments. The appellate order relied upon by the department did not alter the assessment or supply new facts; it only contained an unimplemented opinion on valuation. On principle, a change of view on the same facts does not amount to information for reopening completed proceedings.

Conclusion: A mere expression of opinion by the Central Board of Revenue does not constitute information within section 59(b) of the Estate Duty Act, 1953.

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