INDIAN AND EASTERN NEWSPAPER SOCIETY NEW DELHI vs COMMISSIONER OF INCOME TAX, NEW DELHI

The Supreme Court held that under Section 147(b) of the Income Tax Act, 1961, the opinion of the internal audit organization cannot be considered as 'information' for reopening an assessment. The Court emphasized that 'information' must consist of facts or legal principles derived from an external source, and the audit opinion does not meet this criterion. Consequently, the Income Tax officer's reassessment based on the audit report was deemed unjustified, and the appeal was allowed, reversing the Tribunal's decision.