Change of opinion on the same material is not "information" for reassessment under section 147(b).

Reassessment under section 147(b) was held invalid where the reopening rested only on a reconsideration of the same material used in the original assessments. The Tribunal found that no fresh facts or new information had emerged after the original allowance of extra shift allowance on electrical machinery, so the action was based on a mere change of opinion. Applying the later Supreme Court view, it held that such reconsideration does not constitute "information" sufficient to justify reassessment under section 147(b). The assessee therefore succeeded on the reopening issue.

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Issues: Whether the reopening of the assessments under section 147(b) was valid when no fresh facts had come to light and the reassessment was based only on a reconsideration of the same material.

Analysis: The original assessments had allowed extra shift allowance on electrical machinery. The subsequent reopening was founded on the view that the allowance had been wrongly granted, but the record showed that no new material or fresh information had emerged between the original assessments and the reopening. On those facts, the reassessment was only a change of opinion on the same material already considered. The Tribunal followed the later Supreme Court view that such reconsideration does not amount to "information" sufficient to justify action under section 147(b).

Conclusion: The reopening was invalid and the assessee succeeded on the issue.

Ratio Decidendi: Reassessment under section 147(b) cannot be sustained when it is initiated merely because the assessing authority has changed its opinion on the same material without any fresh information or new facts.

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