https://www.taxtmi.com/caselaws?id=39759 Reassessment under section 147(b) may rest on subsequent factual or legal guidance received through competent governmental channels external to the assessing officer, rather than a mere change of opinion. Where an assessee's original representation incorrectly states the factual basis for a deduction, later clarification from revenue audit and legal authorities can constitute information supporting reassessment under section 148. Writ relief under article 226 remains discretionary and may be refused where the taxpayer's conduct caused the erroneous allowance, equitable entitlement is absent, or intervention would permit unjust enrichment at public expense. The reassessment notice was upheld and writ relief declined on both jurisdictional and discretionary grounds. en-us Tue, 10 Dec 1974 00:00:00 +0530 Tue, 20 Apr 2010 11:28:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39759 Reassessment under section 147(b) may rest on subsequent factual or legal guidance received through competent governmental channels external to the assessing officer, rather than a mere change of opinion. Where an assessee's original representation incorrectly states the factual basis for a deduction, later clarification from revenue audit and legal authorities can constitute information supporting reassessment under section 148. Writ relief under article 226 remains discretionary and may be refused where the taxpayer's conduct caused the erroneous allowance, equitable entitlement is absent, or intervention would permit unjust enrichment at public expense. The reassessment notice was upheld and writ relief declined on both jurisdictional and discretionary grounds. Case-Laws Income Tax Tue, 10 Dec 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39759