https://www.taxtmi.com/caselaws?id=8912 Reassessment was held valid where the original assessment had been made without considering the relevant trust income provision and the assessing authority later received information showing the trust beneficiaries to be an indeterminate and fluctuating body. On that basis, the reopening was treated as more than a mere change of opinion and was upheld under section 147(b). The income from the trust fund was also held liable to assessment at the maximum rate under the proviso to section 41(1), because the beneficiaries' shares were indeterminate and unknown. Both issues were decided against the assessee, and the reassessment at the maximum rate was sustained. en-us Mon, 08 Jan 1973 00:00:00 +0530 Fri, 04 Mar 2016 18:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8912 Reassessment was held valid where the original assessment had been made without considering the relevant trust income provision and the assessing authority later received information showing the trust beneficiaries to be an indeterminate and fluctuating body. On that basis, the reopening was treated as more than a mere change of opinion and was upheld under section 147(b). The income from the trust fund was also held liable to assessment at the maximum rate under the proviso to section 41(1), because the beneficiaries' shares were indeterminate and unknown. Both issues were decided against the assessee, and the reassessment at the maximum rate was sustained. Case-Laws Income Tax Mon, 08 Jan 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8912