Subsequent tribunal rulings as "information" can justify reassessment where they reveal the legal character of transactions.

A subsequent Tribunal decision on the legal character of the same type of transaction can constitute "information" for reopening if it brings external knowledge to the Income-tax Officer after the original assessment. Reassessment under section 34(1)(b) is not justified by a mere change of opinion on the same materials, but here the later rulings on pucca delivery orders altered the legal understanding of the transactions and supplied information bearing on escaped income. Because the matter involved a mixed question of law and fact, the later view could properly support reopening, and the reassessment was justified.

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Issues: Whether a later Tribunal decision taking a different view on the legal character of the same type of transaction could constitute "information" within the meaning of section 34(1)(b) of the Indian Income-tax Act, 1922, so as to justify reopening of the assessment.

Analysis: For reopening under section 34(1)(b), the Income-tax Officer must receive knowledge or instruction from an external source after the original assessment, whether on fact or law, from which a reasonable belief may be formed that income had escaped assessment or been under-assessed. A mere change of opinion is not enough. On the facts here, the later Tribunal decisions altered the legal understanding of the effect of pucca delivery orders and were treated as information bearing on the true legal character of the transactions. The question was not confined to a pure question of fact, but involved a mixed question of law and fact, so the later view could properly inform the reopening.

Conclusion: The later Tribunal decisions constituted information within section 34(1)(b), and the reopening of the assessment was justified.

Ratio Decidendi: A subsequent authoritative decision on the legal character of a transaction can amount to information for reassessment purposes if it supplies the Income-tax Officer with external knowledge after the original assessment, and a mere change of opinion on the same materials is insufficient only where no such external information exists.

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