Primary facts disclosed, reassessment under section 147(a) fails where no material non-disclosure is shown.

Where the assessee disclosed all primary facts, reassessment under section 147(a) could not be sustained merely because the Revenue later took a different view on interest on securities and provision for foreign exchange entitlement certificates. The text notes that the assessee had furnished all material particulars at the original assessment stage, there was no suppression of material facts, and the same accounting method had been consistently followed year after year. On that basis, the assessee's treatment of both items was accepted on the merits, and no escapement of income or underassessment was shown.

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Issues: Whether reassessment under section 147(a) was sustainable when the assessee had disclosed the primary facts relating to interest on securities and provision for foreign exchange entitlement certificates, and whether the assessee's method of accounting for these items was legally acceptable.

Analysis: The assessee had placed all material particulars before the Income-tax Officer at the time of the original assessment. The Tribunal found that there was no suppression of any fact, material or otherwise, and that the same method of computation had been consistently followed year after year. It further held that the assessee's treatment of interest on securities and the provision for foreign exchange entitlement certificates was valid on the merits and that there was no basis to presume escapement of income or underassessment.

Conclusion: Reassessment under section 147(a) was not justified, and the assessee's accounting treatment of the two items was upheld.

Final Conclusion: The reference was answered in favour of the assessee and against the Revenue, with costs awarded to the assessee.

Ratio Decidendi: Where the assessee has disclosed all primary facts and the Revenue seeks reopening without any nondisclosure of material facts, jurisdiction under section 147(a) cannot be assumed.

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