https://www.taxtmi.com/caselaws?id=36533 A completed income-tax assessment cannot be reopened under section 34(1)(b) of the Indian Income-tax Act, 1922 merely because the Income-tax Officer later reappraises the same material and reaches a different view. Reopening requires both a belief that income has escaped assessment and information in the officer's possession that was not earlier considered. On the facts, the assessee had disclosed the primary facts about ownership of the building, partial use by its mining department, and receipt of rent, and no fresh information or newly discovered material supported the reassessment. The reopening was therefore only a change of opinion and was not competent. en-us Tue, 08 Apr 1980 00:00:00 +0530 Tue, 23 Mar 2010 10:39:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36533 A completed income-tax assessment cannot be reopened under section 34(1)(b) of the Indian Income-tax Act, 1922 merely because the Income-tax Officer later reappraises the same material and reaches a different view. Reopening requires both a belief that income has escaped assessment and information in the officer's possession that was not earlier considered. On the facts, the assessee had disclosed the primary facts about ownership of the building, partial use by its mining department, and receipt of rent, and no fresh information or newly discovered material supported the reassessment. The reopening was therefore only a change of opinion and was not competent. Case-Laws Income Tax Tue, 08 Apr 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36533