https://www.taxtmi.com/caselaws?id=39545 Reassessment is permissible where material already on record was not actually considered in the original assessment and the reopening is not a mere change of opinion. On dissolution of a trading firm, stock-in-trade retains its character as stock-in-trade and must be valued at market price for computing trading results, so the revaluation surplus is taxable as revenue income. Departmental circulars may guide administration but cannot control quasi-judicial assessment functions unless they are consistent with the statute and do not fetter discretion. On all three points, the Revenue's position was upheld. en-us Fri, 10 Jan 1975 00:00:00 +0530 Sat, 17 Apr 2010 12:01:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39545 Reassessment is permissible where material already on record was not actually considered in the original assessment and the reopening is not a mere change of opinion. On dissolution of a trading firm, stock-in-trade retains its character as stock-in-trade and must be valued at market price for computing trading results, so the revaluation surplus is taxable as revenue income. Departmental circulars may guide administration but cannot control quasi-judicial assessment functions unless they are consistent with the statute and do not fetter discretion. On all three points, the Revenue's position was upheld. Case-Laws Income Tax Fri, 10 Jan 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39545