https://www.taxtmi.com/caselaws?id=5206 For reopening under Section 147(b) of the Income-tax Act, "information" must derive from a source competent to state the law or disclose relevant facts. An internal audit party performs administrative functions and its view on the interpretation or application of law is not, by itself, information within that provision. It may draw the Assessing Officer's attention to a provision or factual matter, but the officer must independently apply his mind and cannot reopen an assessment merely because he has changed his opinion on material already considered. Reassessment on the basis of the audit party's legal opinion is therefore not justified. en-us Fri, 31 Aug 1979 00:00:00 +0530 Tue, 03 Jun 2025 08:44:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5206 For reopening under Section 147(b) of the Income-tax Act, "information" must derive from a source competent to state the law or disclose relevant facts. An internal audit party performs administrative functions and its view on the interpretation or application of law is not, by itself, information within that provision. It may draw the Assessing Officer's attention to a provision or factual matter, but the officer must independently apply his mind and cannot reopen an assessment merely because he has changed his opinion on material already considered. Reassessment on the basis of the audit party's legal opinion is therefore not justified. Case-Laws Income Tax Fri, 31 Aug 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5206