https://www.taxtmi.com/caselaws?id=37491 Reopening under section 147(b) is sustainable where the Income-tax Officer has subsequent information after the original assessment and that information gives reason to believe income escaped assessment; a mere change of opinion is not enough, but later factual or legal material can support jurisdiction. On the property issue, the lease deed and assignment had to be read as a whole, and the repeated use of sub-lease language, retention of rent and municipal obligations, and reserved reversionary rights showed that the transaction was not an outright sale. The assessee was therefore treated as the owner of the superstructure for section 22 and the house-property income was assessable in its hands. en-us Tue, 21 Feb 1978 00:00:00 +0530 Tue, 30 Mar 2010 11:37:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37491 Reopening under section 147(b) is sustainable where the Income-tax Officer has subsequent information after the original assessment and that information gives reason to believe income escaped assessment; a mere change of opinion is not enough, but later factual or legal material can support jurisdiction. On the property issue, the lease deed and assignment had to be read as a whole, and the repeated use of sub-lease language, retention of rent and municipal obligations, and reserved reversionary rights showed that the transaction was not an outright sale. The assessee was therefore treated as the owner of the superstructure for section 22 and the house-property income was assessable in its hands. Case-Laws Income Tax Tue, 21 Feb 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37491