https://www.taxtmi.com/caselaws?id=166243 The expression "information" in section 34(1)(b) of the Indian Income-tax Act, 1922 includes both facts and law. A material fact already recorded in the assessment papers does not cease to be information because the Income-tax Officer earlier failed to appreciate its significance. Where the officer later becomes aware for the first time of the factual position and its statutory effect, and that awareness leads him to believe excessive relief was granted, the reassessment is not a mere change of opinion. On those facts, the reassessment was valid and the reference was answered in favour of the Revenue. en-us Mon, 22 Aug 1966 00:00:00 +0530 Mon, 04 May 2015 10:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=166243 The expression "information" in section 34(1)(b) of the Indian Income-tax Act, 1922 includes both facts and law. A material fact already recorded in the assessment papers does not cease to be information because the Income-tax Officer earlier failed to appreciate its significance. Where the officer later becomes aware for the first time of the factual position and its statutory effect, and that awareness leads him to believe excessive relief was granted, the reassessment is not a mere change of opinion. On those facts, the reassessment was valid and the reference was answered in favour of the Revenue. Case-Laws Income Tax Mon, 22 Aug 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=166243