https://www.taxtmi.com/caselaws?id=35812 An audit note that merely expressed disagreement with the Income-tax Officer's earlier treatment of items as borrowings under rule 2 of the Second Schedule did not constitute valid "information" under section 8(b). Where the original assessments had already considered that provision and adopted the same capital computation, reopening on the same material was only a reconsideration of an earlier decision. The High Court held that reassessment could not be founded on such audit opinion, and the notices issued to reopen the completed assessments were without jurisdiction and liable to be quashed. en-us Wed, 30 Jul 1980 00:00:00 +0530 Tue, 16 Mar 2010 17:47:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35812 An audit note that merely expressed disagreement with the Income-tax Officer's earlier treatment of items as borrowings under rule 2 of the Second Schedule did not constitute valid "information" under section 8(b). Where the original assessments had already considered that provision and adopted the same capital computation, reopening on the same material was only a reconsideration of an earlier decision. The High Court held that reassessment could not be founded on such audit opinion, and the notices issued to reopen the completed assessments were without jurisdiction and liable to be quashed. Case-Laws Income Tax Wed, 30 Jul 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35812