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    <title>1967 (11) TMI 9 - Supreme Court</title>
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    <description>Reopening of assessment was valid where the Income-tax Officer acted on external information from judicial decisions in related proceedings showing that the assessee&#039;s interest income was received as a financier and not as a partner. That material was not a mere change of opinion on facts already considered; it constituted information within the reopening provision even though the underlying facts could earlier have been found on the record. The challenge to jurisdiction therefore failed, and the assessment could be reopened on that basis.</description>
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      <link>https://www.taxtmi.com/caselaws?id=5091</link>
      <description>Reopening of assessment was valid where the Income-tax Officer acted on external information from judicial decisions in related proceedings showing that the assessee&#039;s interest income was received as a financier and not as a partner. That material was not a mere change of opinion on facts already considered; it constituted information within the reopening provision even though the underlying facts could earlier have been found on the record. The challenge to jurisdiction therefore failed, and the assessment could be reopened on that basis.</description>
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      <pubDate>Wed, 22 Nov 1967 00:00:00 +0530</pubDate>
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