https://www.taxtmi.com/caselaws?id=37205 For reopening a gift-tax assessment, section 16(1)(b) requires both a belief that taxable gift has escaped assessment and post-assessment information supporting that belief. The text states that "information" can include an external quasi-judicial determination, including an appellate order on the same property for the immediately preceding year. On that basis, the appellate order in the wealth-tax proceedings was treated as valid information, so reopening was upheld. Because the reassessment was founded on that fresh information and not on a mere change of opinion, the Tribunal's order quashing the reassessment was held to be incorrect. en-us Wed, 26 Sep 1979 00:00:00 +0530 Sat, 27 Mar 2010 13:58:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37205 For reopening a gift-tax assessment, section 16(1)(b) requires both a belief that taxable gift has escaped assessment and post-assessment information supporting that belief. The text states that "information" can include an external quasi-judicial determination, including an appellate order on the same property for the immediately preceding year. On that basis, the appellate order in the wealth-tax proceedings was treated as valid information, so reopening was upheld. Because the reassessment was founded on that fresh information and not on a mere change of opinion, the Tribunal's order quashing the reassessment was held to be incorrect. Case-Laws Income Tax Wed, 26 Sep 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37205