Revised requisition compensation treated as house property income, and reopening upheld when definite escapement information emerged later.

Statutory compensation for requisitioned immovable property, when revised under the governing requisition law, retained the same character as the original recurring compensation and was treated as rent-like receipt for house property taxation under section 23 of the Income-tax Act, 1961. The enhanced amount was therefore taxable as income from house property in the earlier assessment years. Reassessment under section 147(b) was also valid because definite information about the escapement emerged only after the original assessments, and the material in the assessee's accounts was too vague and incomplete to bar reopening.

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Issues: Whether the reassessment under section 147(b) was valid and whether the enhanced compensation received for requisitioned property was taxable as income from house property in the relevant earlier assessment years.

Analysis: The enhanced compensation was payable under the Requisitioning and Acquisition of Immovable Property Act, 1952 and was not a discretionary or ex gratia payment. The requisitioned property, in substance, stood in a relationship akin to a lease for the purposes of section 23 of the Income-tax Act, 1961, and the recurring compensation represented rent or rent-receivable for annual value computation. The revised compensation retained the same character as the original compensation earlier assessed as house property income. The information regarding the enhanced compensation became definite and concrete only after the original assessments, and the material in the assessee's accounts was too vague and incomplete to disable reopening under section 147(b).

Conclusion: The reassessment was valid, and the enhanced compensation was rightly brought to tax as income from house property in the earlier assessment years; the challenge failed.

Ratio Decidendi: Where statutory compensation for requisitioned property is revised under the governing requisition law, the enhanced amount partakes the same character as the original recurring compensation for house property taxation, and reassessment is permissible when definite information of escapement is received after the original assessment.

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