Dismissing the appeal of the revenue the Court held that opinion of internal audit party of income tax department cannot be recorded as information within the meaning of section 147(b) for reopening of assessment .  Court held that true evaluation of the law in its bearing on the assessment must be made directly and solely by the Income -tax officer . Order of Tribunal is affirmed . Followed Indian & Eastern News Paper Society ( 1979) 2 taxman 197 (SC), Jainam Investments v. ACIT ( 2021) 439 ITR 154 ( Bom)( HC)