Reassessment under section 34(1)(b) requires later-acquired information; reopening failed where all relevant facts were already disclosed.

Reassessment under section 34(1)(b) of the Indian Income-tax Act, 1922 is permissible only where the Income-tax Officer has received information after the original assessment. Because the relevant facts, including receipt of guests' charges from members, were already before the officer when the original assessments were made, and no material showed any later-acquired information, the statutory condition for reopening was not met. The reassessment proceedings were therefore invalid and the issue was decided in favour of the assessee.

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Issues: Whether reassessment under section 34(1)(b) of the Indian Income-tax Act, 1922 was valid in the absence of material showing that the Income-tax Officer had received fresh information after the original assessments.

Analysis: Reassessment under section 34(1)(b) can be initiated only if the Income-tax Officer receives information subsequent to the original assessment. Where all relevant facts, including the receipt of guests' charges from members, were already before the officer at the time of the original assessments and no material was shown to establish later-acquired information, the statutory condition for reopening is not satisfied.

Conclusion: The reassessment proceedings under section 34(1)(b) were invalid and the issue was decided in favour of the assessee.

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