https://www.taxtmi.com/caselaws?id=38573 Reopening under section 147(b) requires fresh information coming into the Income-tax Officer's possession after the original assessment; a mere change of opinion on the same material does not confer jurisdiction. On the facts stated, the reassessment was therefore invalid and without jurisdiction. The Tribunal's denial of development rebate on conversion materials and related machinery also failed because its factual finding lacked evidentiary support, and the earlier decision did not create a universal rule for such items. The record did not establish that the statutory conditions for denying the rebate were met, so the assessee's claim was upheld. en-us Wed, 18 Aug 1976 00:00:00 +0530 Wed, 07 Apr 2010 13:04:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38573 Reopening under section 147(b) requires fresh information coming into the Income-tax Officer's possession after the original assessment; a mere change of opinion on the same material does not confer jurisdiction. On the facts stated, the reassessment was therefore invalid and without jurisdiction. The Tribunal's denial of development rebate on conversion materials and related machinery also failed because its factual finding lacked evidentiary support, and the earlier decision did not create a universal rule for such items. The record did not establish that the statutory conditions for denying the rebate were met, so the assessee's claim was upheld. Case-Laws Income Tax Wed, 18 Aug 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38573