https://www.taxtmi.com/caselaws?id=8798 Reopening of a completed assessment under section 34(1)(b) was impermissible where the Income-tax Officer already had before him all material facts relied on for the original assessments, including the borrowings, investment of part of those funds in the agency firm, common partners, and absence of interest. The requirement was fresh information giving reason to believe that income had escaped assessment, and the Explanation to section 34(1) did not help because the issue was not lack of diligence in finding primary facts but the absence of new information. A later different view in a subsequent assessment was only a change of opinion and could not justify reassessment. en-us Mon, 02 Oct 1972 00:00:00 +0530 Thu, 04 Jun 2009 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8798 Reopening of a completed assessment under section 34(1)(b) was impermissible where the Income-tax Officer already had before him all material facts relied on for the original assessments, including the borrowings, investment of part of those funds in the agency firm, common partners, and absence of interest. The requirement was fresh information giving reason to believe that income had escaped assessment, and the Explanation to section 34(1) did not help because the issue was not lack of diligence in finding primary facts but the absence of new information. A later different view in a subsequent assessment was only a change of opinion and could not justify reassessment. Case-Laws Income Tax Mon, 02 Oct 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8798