https://www.taxtmi.com/caselaws?id=170600 A completed and final estate duty assessment could not be reopened under amended section 59 because the provision contained no clear retrospective language or necessary implication. Section 62 also did not justify the notice, as the alleged error was not a self-evident mistake apparent from the record but required reconsideration of material already assessed, which amounted to a change of opinion. Rule 15 of the Controlled Companies Rules likewise did not supply fresh information for reopening, since the relevant facts were already before the assessing authority and the deceased was found not to control the company within that rule. The reassessment notice was therefore without jurisdiction. en-us Mon, 30 Jan 1967 00:00:00 +0530 Thu, 04 Jun 2015 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=170600 A completed and final estate duty assessment could not be reopened under amended section 59 because the provision contained no clear retrospective language or necessary implication. Section 62 also did not justify the notice, as the alleged error was not a self-evident mistake apparent from the record but required reconsideration of material already assessed, which amounted to a change of opinion. Rule 15 of the Controlled Companies Rules likewise did not supply fresh information for reopening, since the relevant facts were already before the assessing authority and the deceased was found not to control the company within that rule. The reassessment notice was therefore without jurisdiction. Case-Laws Income Tax Mon, 30 Jan 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=170600