Reassessment under section 147(b) needs subsequent information; a mere original assessment error cannot justify reopening.

Reassessment under section 147(b) requires subsequent information as a precedent condition, even where the original assessment is alleged to contain an error of law or an excessive deduction. A mere mistake or oversight in the original assessment does not by itself justify reopening; the information must come from an external source, the existing record, or further factual or legal investigation. On the stated facts, no such information reaching the Income-tax Officer before reopening was established. If the issue was only a patent error, rectification was the proper course rather than reassessment.

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Issues: Whether reassessment under section 147(b) of the Income-tax Act could be validly initiated in the absence of any subsequent information, merely because the original assessment allegedly allowed an excessive deduction due to an error of law.

Analysis: The Tribunal read the governing Supreme Court authority as requiring information as a precedent condition for invoking section 147(b). It held that the existence of a mistake or oversight in the original assessment, by itself, does not dispense with the need for subsequent information derived from an external source, from material on record, or from further investigation into the facts or law. On the facts, the revenue failed to establish any such information reaching the Income-tax Officer before reopening. If the point was only a patent error in the original assessment, the proper course would have been rectification rather than reassessment.

Conclusion: Reassessment under section 147(b) was not validly initiated, and the reopening was quashed in favour of the assessee.

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