https://www.taxtmi.com/caselaws?id=38576 Reopening under section 34(1)(b) of the Indian Income-tax Act, 1922 is valid only where the Income-tax Officer has fresh information, including material from the record or an external source, leading to a reasonable belief that income has escaped assessment. A mere re-examination of the same material, without discovery of new facts, mistake, oversight, or subsequent information, does not confer jurisdiction. On the facts, no clear fresh information or demonstrated error in the original assessment was shown, and the clubbing issue was one on which two views were possible. The reassessment could not therefore rest on a mere change of opinion, and the reference was answered in favour of the assessee. en-us Mon, 22 Nov 1976 00:00:00 +0530 Wed, 07 Apr 2010 13:16:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38576 Reopening under section 34(1)(b) of the Indian Income-tax Act, 1922 is valid only where the Income-tax Officer has fresh information, including material from the record or an external source, leading to a reasonable belief that income has escaped assessment. A mere re-examination of the same material, without discovery of new facts, mistake, oversight, or subsequent information, does not confer jurisdiction. On the facts, no clear fresh information or demonstrated error in the original assessment was shown, and the clubbing issue was one on which two views were possible. The reassessment could not therefore rest on a mere change of opinion, and the reference was answered in favour of the assessee. Case-Laws Income Tax Mon, 22 Nov 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38576