https://www.taxtmi.com/caselaws?id=6633 Reopening was upheld because the Income-tax Officer acted on fresh information from the inspector's report, which was not before him at the original assessment. The report gave concrete details on staff time spent on exempt and non-exempt receipts, and on the collection and incurring of cabin receipts and electricity charges, supporting a belief that expenses linked to exempt income had been wrongly allowed and loss had been overstated. On those facts, the court held that the notice was not based on a mere change of opinion. The reassessment proceedings were therefore valid, and the challenge to the notice failed. en-us Tue, 07 Dec 1965 00:00:00 +0530 Tue, 27 Jan 2009 17:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6633 Reopening was upheld because the Income-tax Officer acted on fresh information from the inspector's report, which was not before him at the original assessment. The report gave concrete details on staff time spent on exempt and non-exempt receipts, and on the collection and incurring of cabin receipts and electricity charges, supporting a belief that expenses linked to exempt income had been wrongly allowed and loss had been overstated. On those facts, the court held that the notice was not based on a mere change of opinion. The reassessment proceedings were therefore valid, and the challenge to the notice failed. Case-Laws Income Tax Tue, 07 Dec 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6633