A.L.A. FIRM vs COMMISSIONER OF INCOME TAX, MADRAS

The Supreme Court upheld the validity of reassessment proceedings under Section 147(b) of the Income Tax Act, 1961, affirming that the Income Tax Officer can act on a mere change of opinion as per the principles established in Kalyanji Mavji's case. The Court clarified that the reassessment was justified as the Income Tax Officer formed an opinion based on new information regarding the revaluation of assets that was not previously considered. The appeal by the assessee was dismissed, affirming the High Court's decision.