https://www.taxtmi.com/caselaws?id=7067 A return already accepted by the department as valid cannot later be treated as no return or an invalid return to invoke reassessment for omission or failure under section 34(1)(a) of the Income-tax Act, 1922, so reopening on that ground was not justified. By contrast, section 34(1)(b) permits reassessment where post-assessment information gives reason to believe income has escaped assessment, and such information may include a later appellate or tribunal decision determining the correct person assessable. Where that decision shows the income was assessed in the hands of the wrong person, it can lawfully support reopening, and this is not a mere change of opinion. en-us Wed, 27 Sep 1967 00:00:00 +0530 Sun, 08 Feb 2009 11:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7067 A return already accepted by the department as valid cannot later be treated as no return or an invalid return to invoke reassessment for omission or failure under section 34(1)(a) of the Income-tax Act, 1922, so reopening on that ground was not justified. By contrast, section 34(1)(b) permits reassessment where post-assessment information gives reason to believe income has escaped assessment, and such information may include a later appellate or tribunal decision determining the correct person assessable. Where that decision shows the income was assessed in the hands of the wrong person, it can lawfully support reopening, and this is not a mere change of opinion. Case-Laws Income Tax Wed, 27 Sep 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7067