case, the Income-tax Officer who re-opened the assessment had definite information within the meaning of Section 34 of the Indian Income ... that he proposed to re-assess the income in consequence of definite information that had come into his possession. It is admitted that
stood thus :
"34. (1) If in consequence of definite information which has come into his possession the Income-tax Officer discovers that income, profits ... Income-tax Officer must come into possession of a "definite information" and secondly that by reason of that he should "discover
opinion, such information without any
supporting document or report can be said to be general and
vague information only and not definite and relevant
information ... conclusion stated therein.
(5) The information in the letter is only general and vague information.
(6) There is no definite or relevant information
revealed that before filing of the returns, the Department had no definite information or had not detected any concealment. Considering that the same ... reveal that before filing of the returns, the Department had no definite information or had not detected any concealment.
14. The word 'conceal
Here in this case, as reiterated
several times there was a definite information and material found qua the
assessee which at least needed verification ... core reason for reopening the
assessment was that there was a definite information and document along with
appraisal report received from the office
empowered to reopen the assessment on the basis of "definite
information". Though this judgment is based on the phraseology of
section ... amendment made in 1948. In that year, the words "definite
information" were replaced by the words "reason to believe". While
expatiating
empowered to
reopen the assessment on the basis of "definite information". Though this
judgment is based on the phraseology of section ... amendment made in 1948. In that
year, the words "definite information" were replaced by the words "reason
to believe". While expatiating
contention of the assessee. According to him, there was a
definite information from the Investigation Wing, therefore, the re-opening
is made on the definite ... learned authorized representative and submitted that there is a
definite information received by the Assessing Officer in the letter that
assessee has paid
assessment simply on the Audit note but he himself had definite information that in the present cases there was escapement of income. The learned departmental ... independently applied his mind and after considering the definite information which came to his possession, subsequent to the original assessment orders, has reason to believe
belief regarding escapement of income. The fact that the words "definite
information" which were there in section ... assessee from assessment. The fact that the words "definite
information" which were there in section