https://www.taxtmi.com/caselaws?id=27359 Reopening under section 147(b) cannot rest on an audit note that merely disputes the interpretation of rule 19(5) used in granting relief under section 84, because a change of opinion on the same material is not "information" for reassessment. The original assessments had applied the average assets and liabilities method, and the audit objection introduced no fresh factual material. The same principle applied to the surtax assessments, which depended entirely on the validity of the income-tax reopening. The reassessment proceedings were therefore not sustainable. en-us Fri, 08 Mar 1985 00:00:00 +0530 Fri, 12 Feb 2010 13:17:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27359 Reopening under section 147(b) cannot rest on an audit note that merely disputes the interpretation of rule 19(5) used in granting relief under section 84, because a change of opinion on the same material is not "information" for reassessment. The original assessments had applied the average assets and liabilities method, and the audit objection introduced no fresh factual material. The same principle applied to the surtax assessments, which depended entirely on the validity of the income-tax reopening. The reassessment proceedings were therefore not sustainable. Case-Laws Income Tax Fri, 08 Mar 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27359