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    <title>1970 (11) TMI 6 - DELHI High Court</title>
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    <description>Reopening under section 34(1)(b) of the Income-tax Act, 1922 was considered valid where the original assessment record did not show that the Income-tax Officer had formed any definite opinion on the taxability of the material in question. The court applied the principle that reassessment is permitted when later information leads to a belief that income has escaped assessment, but not where the officer merely changes a concluded view. On the facts, the material had been available earlier, yet the record suggested uncertainty rather than a final determination, so the reassessment was upheld.</description>
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    <pubDate>Mon, 16 Nov 1970 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=8049</link>
      <description>Reopening under section 34(1)(b) of the Income-tax Act, 1922 was considered valid where the original assessment record did not show that the Income-tax Officer had formed any definite opinion on the taxability of the material in question. The court applied the principle that reassessment is permitted when later information leads to a belief that income has escaped assessment, but not where the officer merely changes a concluded view. On the facts, the material had been available earlier, yet the record suggested uncertainty rather than a final determination, so the reassessment was upheld.</description>
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      <pubDate>Mon, 16 Nov 1970 00:00:00 +0530</pubDate>
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