Reassessment on mere change of opinion is invalid where reopening relies only on facts already on record.

Reopening of an estate duty assessment under section 59(b) was invalid where the audit objection did not disclose new material but only re-evaluated facts already on record, including the valuation details of the land and constructed portion. The original assessment had before it the relevant factual material, and the later objection merely expressed a different view on how much land was appurtenant to the building. A reassessment based only on a fresh application of mind to the same material does not amount to receipt of information within the provision, so reopening on a mere change of opinion was not justified.

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Issues: Whether reopening of the estate duty assessment under section 59(b) was valid when the audit objection only re-evaluated facts already available in the original valuation report.

Analysis: The factual material concerning the property valuation, including the total land area and the constructed portion, was already before the assessing authority during the original assessment. The audit objection did not supply new factual information; it only expressed a different view on how much land should be treated as appurtenant to the building. Reopening on that basis amounted to a fresh application of mind to the same material and not the receipt of information within the meaning of the provision.

Conclusion: Reopening under section 59(b) was not justified and was invalid.

Ratio Decidendi: Reassessment cannot be sustained where the authority seeks to reopen the matter merely on a change of opinion on facts already on record, and not on the basis of fresh information.

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