Reassessment on omitted statutory disallowance upheld where the Assessing Officer later found the original assessment had missed it.

Reassessment under section 147(b) was upheld because the assessee's foreign buyers' entertainment expenditure was already on record in the original assessment, and the Assessing Officer later discovered that the statutory disallowance under section 37(2A) had been omitted. A later realisation that a mandatory disallowance was not made can constitute "information" for reopening, even if the original omission arose from inadvertence, negligence, or lack of vigilance. The matter was therefore not treated as a mere change of opinion on the same facts, and the Revenue's objection succeeded.

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Issues: Whether reassessment under section 147(b) was valid where the expenditure had already been disclosed in the original assessment record and the reassessment was founded on the Assessing Officer's later discovery that the disallowance under section 37(2A) ought to have been made.

Analysis: The expenditure on foreign buyers' entertainment was already part of the materials filed in the original assessment proceedings. Explanation 2 to section 37(2A), inserted retrospectively, treated hospitality expenditure as entertainment expenditure. The reassessment was initiated after the Assessing Officer realised that the earlier assessment had omitted the statutory disallowance. Such an omission, even if attributable to inadvertence, negligence, or lack of vigilance, can constitute "information" for the purpose of section 147(b). The case was therefore not one of mere change of opinion on the same facts.

Conclusion: Reassessment under section 147(b) was valid and the objection based on change of opinion failed, in favour of the Revenue.

Ratio Decidendi: An Assessing Officer's later discovery that a statutory disallowance was omitted on facts already on record can amount to "information" justifying reassessment under section 147(b), and the reassessment is not invalid merely because the original omission resulted from inadvertence or negligence.

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