Internal audit opinion cannot trigger reassessment under Section 147(b); reopening requires real information, not a mere change of view.

For reopening under Section 147(b) of the Income-tax Act, "information" must derive from a source competent to state the law or disclose relevant facts. An internal audit party performs administrative functions and its view on the interpretation or application of law is not, by itself, information within that provision. It may draw the Assessing Officer's attention to a provision or factual matter, but the officer must independently apply his mind and cannot reopen an assessment merely because he has changed his opinion on material already considered. Reassessment on the basis of the audit party's legal opinion is therefore not justified.

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Issues: Whether the view expressed by an internal audit party of the Income-tax Department on a point of law can constitute "information" for reopening an assessment under Section 147(b) of the Income-tax Act, 1961.

Analysis: The statutory expression "information" in Section 147(b) includes knowledge of facts or of the true legal position derived from a formal source of law. An internal audit party performs administrative or executive functions and is not a body competent to declare the law. Its opinion on the interpretation or application of law cannot, by itself, amount to "information". At most, it may draw the Income-tax Officer's attention to the relevant legal provision or factual matter. The officer must independently form his own judgment on the legal effect of the material and cannot reopen an assessment merely because he has changed his opinion on the same material already considered earlier.

Conclusion: The opinion of an internal audit party on a point of law is not "information" within Section 147(b), and reassessment on that basis is not legally justified.

Ratio Decidendi: For Section 147(b), "information" must come from a source competent to state the law, and an internal audit party's legal opinion does not satisfy that requirement; reopening cannot rest on a mere change of opinion on material already assessed.

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