https://www.taxtmi.com/caselaws?id=11694 Audit information on a legal issue can justify reopening under section 147(b) of the Income-tax Act, 1961 when the assessing authority independently applies its mind and forms the requisite belief; a mere audit opinion is not enough. The article distinguishes between the audit party's interpretation and communication of legal information, and holds that reassessment is valid where the authority acts on that information after independent consideration. It also notes that, on the facts discussed, the audit material affected entitlement to section 80J relief, including manufacture through another party and compliance with the audit requirement under section 80J(6A), and the reassessment was upheld. en-us Tue, 06 May 2003 00:00:00 +0530 Sat, 06 Feb 2010 10:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11694 Audit information on a legal issue can justify reopening under section 147(b) of the Income-tax Act, 1961 when the assessing authority independently applies its mind and forms the requisite belief; a mere audit opinion is not enough. The article distinguishes between the audit party's interpretation and communication of legal information, and holds that reassessment is valid where the authority acts on that information after independent consideration. It also notes that, on the facts discussed, the audit material affected entitlement to section 80J relief, including manufacture through another party and compliance with the audit requirement under section 80J(6A), and the reassessment was upheld. Case-Laws Income Tax Tue, 06 May 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11694