https://www.taxtmi.com/caselaws?id=8418 Section 34(1)(b) of the Income-tax Act, 1922 required the Income-tax Officer to have reason to believe that income had escaped assessment and that the belief arose from information in his possession. Where the original assessment records already contained all relevant facts and those facts had been consciously considered, a later reassessment based only on a different view of the same material in subsequent years amounted to a mere change of opinion. Such a shift was not "information" for section 34(1)(b), so reopening completed assessments on that basis was without jurisdiction and invalid. en-us Wed, 11 Aug 1971 00:00:00 +0530 Wed, 15 Apr 2009 09:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8418 Section 34(1)(b) of the Income-tax Act, 1922 required the Income-tax Officer to have reason to believe that income had escaped assessment and that the belief arose from information in his possession. Where the original assessment records already contained all relevant facts and those facts had been consciously considered, a later reassessment based only on a different view of the same material in subsequent years amounted to a mere change of opinion. Such a shift was not "information" for section 34(1)(b), so reopening completed assessments on that basis was without jurisdiction and invalid. Case-Laws Income Tax Wed, 11 Aug 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8418