KALYANJI MAVJI & CO vs C.I.T., WEST BENGAL-II

The Supreme Court held that the reopening of an assessment under Section 34(1)(b) of the Income Tax Act, 1922, is valid if the information leading to reassessment is based on subsequent facts or a more careful examination of original assessment materials. The Court found that the Income Tax officer's action was not merely a change of opinion but was justified as the deduction claimed was incorrectly allowed. The High Court's ruling that the reassessment was competent was upheld, affirming the applicability of Section 34(1)(b).