Reassessment requires new information, not a mere change of opinion on the same material already assessed.

Reopening under section 34(1)(b) of the Indian Income-tax Act, 1922 is justified only when the Income-tax Officer receives subsequent information after the original assessment and that information supports a belief that income has escaped assessment. A reassessment cannot be founded on a later officer's different appreciation of the same material already on record, including directors' reports and correspondence, because a mere change of opinion does not amount to statutory information. The operative principle is that jurisdiction to reopen depends on new information, not reappraisal of existing facts.

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Issues: Whether the proceedings initiated under section 34(1)(b) of the Indian Income-tax Act, 1922, were validly reopened on the basis of information in the possession of the Income-tax Officer.

Analysis: The relevant material before the original assessing officer, including the directors' reports and correspondence, already disclosed the existence of Government control over wheat supplies and manufactured products. The subsequent reassessment for a later year was made on the later officer's different appreciation of the same materials, not on any new or external information. The governing principle is that jurisdiction under section 34(1)(b) arises only when the Income-tax Officer receives information after the original assessment and such information leads to the belief that income has escaped assessment; a mere change of opinion on the same record does not satisfy that requirement.

Conclusion: The reopening was not valid, because it was founded only on a change of opinion and not on statutory information within section 34(1)(b).

Final Conclusion: The question referred was answered against the Revenue and the reassessment proceedings were held to be without jurisdiction.

Ratio Decidendi: A reassessment under section 34(1)(b) cannot rest on a mere reappraisal of the same facts by a different assessing officer; only subsequent information, not a change of opinion, can justify reopening.

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