https://www.taxtmi.com/caselaws?id=276156 Reopening of excess profits tax assessments under section 15 required definite information of an objective, previously unknown fact showing that chargeable profits had escaped assessment. An appellate view on material already considered, including conclusions about family partition and business ownership, amounted only to a change of opinion and did not confer reopening jurisdiction. The reassessment was therefore without jurisdiction. Section 10A could operate only within a validly pending assessment proceeding; because the section 15 reopening was invalid, the related annulment of partition under section 10A also failed. The reference was decided in favour of the assessee, with costs. en-us Fri, 22 May 1964 00:00:00 +0530 Wed, 31 Oct 2018 18:29:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276156 Reopening of excess profits tax assessments under section 15 required definite information of an objective, previously unknown fact showing that chargeable profits had escaped assessment. An appellate view on material already considered, including conclusions about family partition and business ownership, amounted only to a change of opinion and did not confer reopening jurisdiction. The reassessment was therefore without jurisdiction. Section 10A could operate only within a validly pending assessment proceeding; because the section 15 reopening was invalid, the related annulment of partition under section 10A also failed. The reference was decided in favour of the assessee, with costs. Case-Laws Income Tax Fri, 22 May 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276156