Reassessment information must relate to the same assessment year; later-year material alone cannot justify reopening completed assessments.

Reassessment under section 147(b) requires information external to the earlier assessment and a rational basis for believing that income escaped assessment for the particular year sought to be reopened. Information obtained during assessment of a later year may support reopening only if it relates to the earlier year in question; a mere change of opinion is not information for this purpose. The High Court may review whether the jurisdictional condition exists, but not reappraise the merits once qualifying information is shown. Reassessment notices were held invalid because the later-year material did not relate to the assessment years sought to be reopened, so the statutory condition was not met.

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Issues: Whether notices for reassessment under section 147(b) of the Income-tax Act, 1961 were valid when the information relied upon was derived from examination of a subsequent assessment year and whether such information had to relate to the same assessment year as the notice.

Analysis: Reopening under section 147(b) requires the Income-tax Officer to have reason to believe that income has escaped assessment in consequence of information. The information must be external to the earlier assessment and must furnish a rational basis for belief concerning the particular assessment year sought to be reopened. Information gathered in the course of assessment proceedings for a later year may be used only if it relates to the earlier year in question. A mere change of opinion does not constitute information within the meaning of the provision, and the High Court may examine whether the jurisdictional condition exists, but not reappraise the merits of the inference once such information is shown to exist.

Conclusion: The notices were invalid because the information derived from the later year did not relate to the assessment years sought to be reopened, and the jurisdictional requirement under section 147(b) was not satisfied.

Ratio Decidendi: Information for reassessment under section 147(b) must be external and must relate to the very assessment year sought to be reopened; information confined to a later year cannot, by itself, justify reopening of an earlier completed assessment.

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