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1971 (5) TMI 29 - HC - Income TaxProceedings initiated under section 34(1)(b) - legality and validity - officer who made the original assessment had full knowledge of the relevant information or facts. The interpretation by the subsequent officer of the existing material amounts only to a change of opinion - it is wellsettled that a mere change of opinion does not constitute information within the meaning of section 34(1)(b). The Income-tax Officer who purported to reopen the assessments did not, therefore, have any information within the meaning of section 34(1)(b) in his, possession, and he, therefore, could not exercise any power or jurisdiction under section 34(1)(b) to reopen the assessments already made. The, reopening of the assessments of the assessee already concluded was, therefore, illegal and not validly done
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