https://www.taxtmi.com/caselaws?id=70205 Reopening under section 147(b) based only on an audit view was invalid where the original assessment had accepted inclusion of interest on borrowed capital in construction cost. The Tribunal applied the principle that a mere change of opinion is not "information" for reassessment, and that an audit opinion on law is only an opinion, not legally cognisable information. On those facts, the reassessment lacked jurisdiction and was held invalid in law. en-us Sat, 05 Dec 1981 00:00:00 +0530 Thu, 14 Apr 2011 18:28:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70205 Reopening under section 147(b) based only on an audit view was invalid where the original assessment had accepted inclusion of interest on borrowed capital in construction cost. The Tribunal applied the principle that a mere change of opinion is not "information" for reassessment, and that an audit opinion on law is only an opinion, not legally cognisable information. On those facts, the reassessment lacked jurisdiction and was held invalid in law. Case-Laws Income Tax Sat, 05 Dec 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70205