https://www.taxtmi.com/caselaws?id=22764 Reopening under section 147(b) requires fresh information received after the original assessment, capable of supporting a reasonable belief that income had escaped assessment. The recorded reasons did not rely on any later appellate order for the relevant subsequent year and instead treated the assessee's explanation as newly disclosed before the appellate authority. That basis amounted only to a change of opinion, not fresh information within the statutory requirement. The reassessment proceedings were therefore invalid and the assumption of jurisdiction under section 147(b) was bad in law. en-us Fri, 17 Aug 1990 00:00:00 +0530 Sat, 12 Dec 2009 17:51:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22764 Reopening under section 147(b) requires fresh information received after the original assessment, capable of supporting a reasonable belief that income had escaped assessment. The recorded reasons did not rely on any later appellate order for the relevant subsequent year and instead treated the assessee's explanation as newly disclosed before the appellate authority. That basis amounted only to a change of opinion, not fresh information within the statutory requirement. The reassessment proceedings were therefore invalid and the assumption of jurisdiction under section 147(b) was bad in law. Case-Laws Income Tax Fri, 17 Aug 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22764