https://www.taxtmi.com/caselaws?id=7825 Reassessment under section 147(b) requires information external to the earlier assessment and a rational basis for believing that income escaped assessment for the particular year sought to be reopened. Information obtained during assessment of a later year may support reopening only if it relates to the earlier year in question; a mere change of opinion is not information for this purpose. The High Court may review whether the jurisdictional condition exists, but not reappraise the merits once qualifying information is shown. Reassessment notices were held invalid because the later-year material did not relate to the assessment years sought to be reopened, so the statutory condition was not met. en-us Tue, 18 Feb 1969 00:00:00 +0530 Thu, 19 Mar 2009 16:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7825 Reassessment under section 147(b) requires information external to the earlier assessment and a rational basis for believing that income escaped assessment for the particular year sought to be reopened. Information obtained during assessment of a later year may support reopening only if it relates to the earlier year in question; a mere change of opinion is not information for this purpose. The High Court may review whether the jurisdictional condition exists, but not reappraise the merits once qualifying information is shown. Reassessment notices were held invalid because the later-year material did not relate to the assessment years sought to be reopened, so the statutory condition was not met. Case-Laws Income Tax Tue, 18 Feb 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7825