Reopening completed assessments requires new information; a mere change of opinion cannot justify reassessment under section 34(1)(b).

Section 34(1)(b) of the Income-tax Act, 1922 required the Income-tax Officer to have reason to believe that income had escaped assessment and that the belief arose from information in his possession. Where the original assessment records already contained all relevant facts and those facts had been consciously considered, a later reassessment based only on a different view of the same material in subsequent years amounted to a mere change of opinion. Such a shift was not "information" for section 34(1)(b), so reopening completed assessments on that basis was without jurisdiction and invalid.

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Issues: Whether the Income-tax Officer had jurisdiction to reopen the completed assessments for the relevant years under section 34(1)(b) of the Income-tax Act, 1922, on the basis of facts already on record and a later view taken in subsequent assessment years.

Analysis: Section 34(1)(b) required two cumulative conditions: the Income-tax Officer must have reason to believe that income had escaped assessment, and that belief must arise in consequence of information in his possession. The original assessment materials contained all relevant facts, and the officer had consciously applied his mind to them when the earlier assessments were made. The later reassessment was triggered only because the officer took a different view of the same facts in subsequent years. Such a shift was not new information within the meaning of the provision, and a mere change of opinion could not justify reopening completed assessments.

Conclusion: The reopening under section 34(1)(b) was without jurisdiction and was invalid.

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