This appeal filed by revenue is Against order of CIT (Appeals) dated 18-10-1983 for assessment year 1975-76, for which previous year ended on 31-3-1975. 2. assessment was originally made on 9-1-1978 on total income of Rs. 3,08,600. In original assessment assessee was allowed development rebate amounting to Rs. 55,018 being 25 per cent of actual cost of freezing plant amounting to Rs. 2,20,071. In words of ITO "later on it was found that freezing plant was installed on 27-3-1975 only and that according to section 16(c) of the, Finance Act, 1974 development rebate on machinery and plant installed after 31-5-1974 but before 1-6-1975 is admissible only if assessee had either purchased or entered into contract for purchase of machinery before first day of December, 1973". ITO noticed that assessee by its letter dated 16-9-1976, during original assessment proceedings, has, however, admitted that there was no contract with suppliers for purchase of freezing plant installed on 27-3-1975 and that order for purchase was placed on 20-6-1974 only. ITO came to conclusion that in those circumstances, assessee was not entitled to development rebate as per section 16(c) of Finance Act, 1974. According to ITO "consequent on this information assessee's income chargeable to t x had escaped assessment within meaning of section 147(b) of Income-tax Act, 1961". He, therefore, initiated proceedings under section 148 by issuing notice on 25-3-1980. In response to said notice assessee filed return on 25-2-1981. assessee in its letter dated 8-11-1976 claimed that n agreement was entered into with M/s Crepaco Inc., U.S.A. as early as in November 1973 and that it was in pursuance of said agreement that American company supplied freezer on 30-9-1974. After giving number of opportunities for producing contract for purchase of plant assessee at last produced invoice No. 47-3157-01 dated 4-10-1974 issued by American company for sale of freezer. assessee wanted invoice to be accepted as evidence of contract having been entered into before 1-12-1973. By relying on mention made in said invoice that sale was made as per Quotation No. 6-307892 dated 20-7-1973. ITO did not agree with this submission of assessee. As assessee has failed to adduce any evidence to show that it entered into contract before 1-12-1973, ITO rejected contentions of assessee and withdrew development rebate of Rs. 55,018 allowed earlier by his reassessment order dated 21-3-1981. 3. Against withdrawal of development rebate in reassessment order, assessee appealed to CIT(A). CIT(A) annulled reassessment observing as under:- "From assessment order it is clear that by letter dated 16-9-1976, appellant had admitted that there was no contract or agreement with suppliers for purchase of Freezing Plant. first assessment was completed only on 9-1-1978 after receipt of this letter. Therefore, whatever information was necessary for coming to correct decision in this case was available with Income-tax Officer when he made first assessment. Income-tax Officer has not pointed out that he has received any information subsequent to completion of assessment which would give him jurisdiction to reopen assessment. Income-tax Officer, therefore, did not have jurisdiction to reopen assessment and so order dated 21st March, 1981 is annulled and appeal allowed." 4. Against above finding of CIT(A) revenue preferred present appeal. At time of hearing departmental representative filed copies of ITO's letter dated 19-8-1976, assessee's letter dated 16-9-1976, assessee's letter dated 8-11-1976, ITO's letter dated 24-11-1976, notes dated 17-11-1977 made by ITO on which lines assessment was made on 9-1- 1978, reasons recorded on 25-3-1980 for reopening under section 147(b) and letter dated 28-6-1978 from ITO to assessee. arguments of departmental representative were to following effect:- By letter dated 19-8-1976 ITO wanted assessee to furnish particulars in respect of date of purchase of Freezing Plant, date of installation of Freezing Plant, date from which it was put to use in business, whether any contract had been entered into for purchase of Freezing Plant earlier and if so, date when contract was entered into with full details and name and address of seller. In response to said letter of ITO assessee replied on 16-9-1976 that date of installation was 27-3-1975, that it was put to use on 27-3-1975, there was no contract, that order was placed on 20-6-1974 with Crepaco Inc., Chicago, U.S.A. assessee, by its letter dated 8-11-1976 informed ITO that it had entered into agreement with seller of Freezer M/s. Crepaco Inc., U.S.A. as early as in November 1973 and that freezer was supplied on 30-9-1974 in pursuance o f said agreement. ITO vide his letter dated 24-11-1976 required assessee to produce agreement said to have been entered into by assessee with M/s Crepaco Inc. in November 1973 and entire correspondence relating to purchase of freezer. agreement alleged to have been entered into by assessee with American company in November 1973 was not produced before ITO. Then there was change in incumbent of office of ITO. successor ITO overlooked earlier correspondence. So, when he made assessment on 9-1-1978 allowed assessee's claim for development rebate. ITO by his letter dated 28-6-1978 brought to notice of assessee provisions of section 16 of Finance Act, 1974 and requested assessee to produce agreement said to have been entered with supplier in November 1973 referred to In its letter dated 8-11-1976. In said letter ITO informed assessee of his proposal to revise assessment by withdrawing development rebate already granted In absence of agreement. Still there was no compliance from assessee for production of agreement said to have been entered in November 1973. Thereafter, ITO recorded reasons on 25-3-1980 for reopening assessment under section 147(b). He issued notice under section 148. As assessee has not produced alleged agreement entered into in November 1973, ITO withdrew development rebate by his reassessment order dated 21-3-1981. assessee had evaded production of contract for purchase of Freezer. This information available to ITO subsequent to making of original assessment on 9-1-1978. succeeding ITO failed to notice correspondence on subject already in file. CIT (A) ought to have found that ITO making original assessment did not apply his mind as to requirement of agreement concluded prior to 1-12-1973 for purchase of Freezer Plant so as to be eligible for development rebate for assessment year 1975-76 in terms of section 16(c) of Finance Act, 1974. Jurisdiction of Income-tax Officer to reassess income arises if he has in consequence of information in his possession reason to believe that income chargeable to tax has escaped assessment. That information must, it is true, have come into possession of Income-tax Officer after previous assessment but even if information be such that it could have been obtained during previous assessment from investigation of material on record, or facts disclosed thereby, or from other enquiry or research Into facts on law, but was not in fact obtained, jurisdiction of Income-tax Officer is not affected. see decision of Supreme Court in CIT v. A. Raman & Co. [1968] 67 ITR 11. For reassessment proceedings under section 147(b) of Income-tax Act, 1961, statute does not require that information must be extraneous to record. It is enough if material on basis of which reassessment proceedings, are sought to be initiated came to notice of Income-tax Officer subsequent to original assessment. See decision of Madras High Court in A.L.A. Firm v. CIT [1976] 102 ITR 622. expression "Information" which was introduced into Indian Income-tax Act, 1922, by amendment of 1939, has not been defined either in 1922 Act or 1961 Act. "To inform" means to "impart knowledge" and detail available to ITO in paper filed before him does not by its mere availability become item of information. It is transmuted into item of information in his possession only if and only when its existence is realised and its implications are recognised. If there was non-advertence of mind on earlier occasion, and advertence on later one that would be sufficient to form foundation for reassessment. See decision of Kerala, High Court in CIT v. Kerala State Industrial Development Corpn. Ltd. [1979] 116 ITR 158. Reference may also be made to decision of Supreme Court in Indo-Aden Salt Mfg. & Trading Co. (P.) Ltd. v. CIT [1986] 159 ITR 624. 5. arguments of assessee's counsel were to following effect: agreement entered into in November 1973 was only oral. Order was placed o n 20-6-1974. All relevant information connected with claim of o n 20-6-1974. All relevant information connected with claim of development rebate was available with ITO when he made original assessment on 9-1-1978. information should be got by ITO from external sources only and not from existing record. In present case as relevant information was in existence in record of ITO section 147(b) is not attracted. 6. We have considered rival submissions. ITO, long after completion of original assessment found out from available record that Freezing was installed on 27-3-1975 and that assessee in its letter dated 16-9-1976 that there was no contract with supplier. They letter dated 28-6- 1978, ITO required assessee to produce agreement with supplier of Freezing Plant said to have been entered into in November 1973 as claimed by assessee in its earlier letter dated 8-11-1976. assessee failed to produce alleged agreement said to have beer. entered into In November 1973. Then ITO initiated proceedings under section 147(b) and issued notice under section 148 on 25-3-1980. information that there was no agreement and claim of assessee as to execution, of agreement in November 1973 was all there already in file of ITO when he made assessment on 9-1-1978. This information was transmuted into item of information in his possession at later date only. Kerala High Court held in case of United Mercantile Co. Ltd. v. CIT [1967] 64 ITR 218 that: "'to inform' means 'to impart knowledge' and detail available to Income-tax Officer in papers filed before him does not by its mere availability become item of information. It is transmuted into item of information in his possession only if, and only when, its existence is realised and its implications are recognised. awareness of Income-tax Officer, for first time, after assessment order of 19th November, 1957, that bonus shares were issued not out of premiums received in cash and consequent result in light of Finance (No. 2) Act, 1957, was information within meaning of that expression as used in section 34(1)(b) of Indian Income-tax Act, 1922, and reopening of assessment order under section 34(1)(b) was not illegal." Later, Kerala High Court held in Kerala State Industrial Development Corpn. Ltd.'s case (supra) that: "If there was non-advertence of mind on earlier occasion and advertence on later one that would be sufficient to form foundation for reassessment." According to ITO information that there was no agreement with suppliers of Freezing Plant came to him subsequent to completion of assessment on 9-1-1978. That is why he mentions in reassessment order dated 21-3-1981 that "Later on, it was found that Freezing Plant was installed on 27-3-1975 only. . . assessee by its letter dated 16-9-1976 has, however, admitted that there was no contract agreement with suppliers for purchase of Freezing Plant installed on 27-3-1975 and that order for purchase was placed on 20-6-1974 only." But we have to see whether ITO, when he completed original assessment was aware of implications of said information or not ITO's letter dated 19-8-1976 clearly shows that he was fully aware of its implications. That is why he asked assessee to furnish details about date of purchase of Freezing Plant, date when it was put to use, whether any contract has been entered into for its purchase earlier, etc. So it cannot be said that there was any inadvertence of ITO's mind on earlier occasion and advertence on later occasion. Even assuming it to be so, in light of decision of Supreme Court in case of Indian & Eastern Newspaper Society v. CIT [1979] 119 ITR 996, how far decision of Kerala High Court in Kerala State Industrial Development Corpn. Ltd.'s case (supra) holds good, is to be examined by Full Bench of Kerala High Court or Supreme Court. Supreme Court in above decision (delivered on 31-8-1979) held as under: "The proposition in decision of Supreme Court in case of Kalyanji Mavji & Co. v. CIT [1976] 102 ITR 287, to effect that case where income had escaped assessment due to 'oversight', 'Inadvertence' or 'mistake' of ITO must fall within s. 34(1)(b) of Indian Income-tax Act, 1922, is stated too widely and travels farther than statute warrants insofar as it can be said to lay down that if, on reappraising material considered by him during original assessment, ITO discovers that he has committed error In consequence of which income has escaped assessment, it is open to him to reopen assessment." Thus, in circumstances of case, we hold that reopening of assessment is not valid and CIT(A) was right in annulling same. 7. In result, appeal is dismissed. *** INCOME TAX OFFICER v. OCEANIC PRODUCTS EXPORTING CO.