https://www.taxtmi.com/caselaws?id=8331 A revenue audit scrutiny note and a letter from the Inspecting Assistant Commissioner were treated as "information" for reopening completed assessments under section 147(b) of the Income-tax Act, 1961. The court distinguished a mere change of opinion on the same material, which cannot justify reassessment, from reopening based on post-assessment information obtained from an external source. It held that "external source" is not limited to judicial decisions or appellate findings and may include statutory audit material and supervisory communications outside the assessing officer's original decision-making process. On that basis, the reassessment was held valid in favour of the Revenue. en-us Mon, 26 Jul 1971 00:00:00 +0530 Thu, 09 Apr 2009 18:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8331 A revenue audit scrutiny note and a letter from the Inspecting Assistant Commissioner were treated as "information" for reopening completed assessments under section 147(b) of the Income-tax Act, 1961. The court distinguished a mere change of opinion on the same material, which cannot justify reassessment, from reopening based on post-assessment information obtained from an external source. It held that "external source" is not limited to judicial decisions or appellate findings and may include statutory audit material and supervisory communications outside the assessing officer's original decision-making process. On that basis, the reassessment was held valid in favour of the Revenue. Case-Laws Income Tax Mon, 26 Jul 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8331