https://www.taxtmi.com/caselaws?id=69619 Reassessment under section 147(b) was held valid where the original assessment had not applied rule 10 or the binding Board instructions governing assessment of a non-resident shipping company. Later communication of the correct legal framework constituted information enabling reopening, because the earlier assessment had ignored the governing rule rather than taken a conscious view on the same material. The reopening was therefore not a mere change of opinion. The authorities relied on the distinction from Simon Carves Ltd. and the principle in Indian & Eastern Newspaper Society to support valid reassessment on subsequently received legal information. en-us Tue, 10 Nov 1981 00:00:00 +0530 Mon, 11 Apr 2011 10:54:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69619 Reassessment under section 147(b) was held valid where the original assessment had not applied rule 10 or the binding Board instructions governing assessment of a non-resident shipping company. Later communication of the correct legal framework constituted information enabling reopening, because the earlier assessment had ignored the governing rule rather than taken a conscious view on the same material. The reopening was therefore not a mere change of opinion. The authorities relied on the distinction from Simon Carves Ltd. and the principle in Indian & Eastern Newspaper Society to support valid reassessment on subsequently received legal information. Case-Laws Income Tax Tue, 10 Nov 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69619