https://www.taxtmi.com/caselaws?id=5279 Reassessment under section 147(b) was valid where information from a later assessment year showed that the original overhead expense computation was erroneous; the material was newly obtained and the reopening was not a mere change of opinion. Direct reassessment against the non-resident assessee was also permissible because the statutory bar on proceeding against the agent after the prescribed time meant those agent proceedings could not preclude action against the assessee itself. Both reassessments were upheld and the challenge failed. en-us Wed, 26 Apr 1989 00:00:00 +0530 Wed, 03 Dec 2025 17:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5279 Reassessment under section 147(b) was valid where information from a later assessment year showed that the original overhead expense computation was erroneous; the material was newly obtained and the reopening was not a mere change of opinion. Direct reassessment against the non-resident assessee was also permissible because the statutory bar on proceeding against the agent after the prescribed time meant those agent proceedings could not preclude action against the assessee itself. Both reassessments were upheld and the challenge failed. Case-Laws Income Tax Wed, 26 Apr 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5279