https://www.taxtmi.com/caselaws?id=27427 A notice reopening an estate duty assessment under section 59 was invalid where no supporting material or information was disclosed to form the required belief. A mere change of opinion could not justify reassessment, and an audit objection could not itself supply the jurisdictional foundation for reopening. An audit note might convey information, but it could not replace the assessing authority's independent satisfaction on the statutory precondition. The notice was therefore quashed. en-us Wed, 01 Aug 1984 00:00:00 +0530 Fri, 12 Feb 2010 17:35:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27427 A notice reopening an estate duty assessment under section 59 was invalid where no supporting material or information was disclosed to form the required belief. A mere change of opinion could not justify reassessment, and an audit objection could not itself supply the jurisdictional foundation for reopening. An audit note might convey information, but it could not replace the assessing authority's independent satisfaction on the statutory precondition. The notice was therefore quashed. Case-Laws Income Tax Wed, 01 Aug 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27427