Reassessment for escaped income requires new post-assessment information, not a mere change of opinion on disclosed material.

Reassessment under section 34(1)(b) of the Income-tax Act, 1922 requires post-assessment information in the Income-tax Officer's possession that justifies the belief that income has escaped assessment. A mere later change of opinion, or failure to notice material already disclosed on the record, is insufficient. On the facts stated, the assessee had disclosed the relevant income and the reopening rested only on a different view taken by a successor officer, so the reassessment was not valid and the result was against the Revenue.

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Issues: Whether reassessment under section 34(1)(b) of the Income-tax Act, 1922 could be sustained when the original assessment had omitted an item of income and the reopening was founded only on a subsequent change of opinion.

Analysis: Reassessment under section 34(1)(b) requires information coming into the Income-tax Officer's possession after the original assessment and that information must justify the belief that income chargeable to tax had escaped assessment. A mere failure to notice material already on record, or a later change of opinion about the same material, does not amount to such information. On the facts found, the assessee had disclosed the relevant income in the return and the reopening was not supported by any new information but only by a different view taken later by the successor officer.

Conclusion: The reopening was not valid under section 34(1)(b) and the answer was against the Revenue.

Ratio Decidendi: Reassessment under section 34(1)(b) cannot rest on a mere change of opinion or on the earlier non-application of mind to material already disclosed on the record; it requires post-assessment information leading to the requisite belief of escaped assessment.

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