Gift-tax reassessment cannot rest on a later valuation report where reopening is only a change of opinion.

An approved valuer's later report on gifted property valuation did not constitute "information" for reopening a gift-tax assessment under section 16(1)(b) where the original assessment had already involved the officer's own opinion on market value. The material was only a further valuation view on the same facts, not a new fact or point of law, so reopening on that basis amounted to an impermissible change of opinion. The reassessment was therefore held invalid, and the assessee's challenge succeeded.

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Issues: Whether an approved valuer's report constituted "information" sufficient to reopen the gift-tax assessment under section 16(1)(b), or whether the reopening was merely a change of opinion on valuation.

Analysis: The valuation of gifted property under section 6 required the Gift-tax Officer to form his own opinion as to market value. The original assessment had already involved an application of mind to the assessee's declared value and the Officer's own estimate. A later valuation report from an approved valuer was only another opinion on the same subject and did not amount to definite information about a new fact or law. Reopening on that basis would merely permit the Officer to revise his earlier valuation opinion, which section 16(1)(b) does not allow.

Conclusion: The approved valuer's report was not information within section 16(1)(b), and the reassessment was invalid. The appeal failed and the assessee succeeded.

Ratio Decidendi: A reassessment based only on a subsequent expert valuation of the same property is impermissible where the original assessment was made on the officer's own opinion; such material is not "information" but only a change of opinion.

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