https://www.taxtmi.com/caselaws?id=36660 Reassessment under section 8(b) of the Companies (Profits) Surtax Act, 1964 was valid only if the Income-tax Officer had post-assessment information satisfying the statutory precondition for reopening. On the facts, the reopening rested on a different view of the same material already examined in the original assessment and the first reassessment, with no fresh external information, no change in law, and no new factual material. A mere second thought or change of opinion could not amount to information conferring jurisdiction to reopen. The reassessment proceedings were therefore not validly initiated, and the issue was decided in favour of the assessee. en-us Thu, 23 Nov 1978 00:00:00 +0530 Tue, 23 Mar 2010 17:17:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36660 Reassessment under section 8(b) of the Companies (Profits) Surtax Act, 1964 was valid only if the Income-tax Officer had post-assessment information satisfying the statutory precondition for reopening. On the facts, the reopening rested on a different view of the same material already examined in the original assessment and the first reassessment, with no fresh external information, no change in law, and no new factual material. A mere second thought or change of opinion could not amount to information conferring jurisdiction to reopen. The reassessment proceedings were therefore not validly initiated, and the issue was decided in favour of the assessee. Case-Laws Income Tax Thu, 23 Nov 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36660