Reassessment based on undisclosed facts fails where all primary material facts were already fully disclosed.

Reassessment under the Income-tax Act could not be sustained where the assessee had disclosed all primary and material facts during the original assessment. On the record, the assessee had placed all relevant materials before the assessing officer, so there was no failure to disclose facts necessary for assessment. In that situation, the statutory basis for reopening was absent, and the reassessment proceedings were held unsustainable in favour of the assessee.

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Issues: Whether notice issued for reassessment under Section 147 of the Income-tax Act, 1961 could be sustained when all primary or material facts had been disclosed in the original assessment.

Analysis: The record showed that the assessee had placed all relevant materials before the assessing officer during the original assessment. On that finding, there was no failure on the part of the assessee to disclose primary or material facts necessary for assessment. In such a situation, reassessment proceedings could not be upheld.

Conclusion: The notice and reassessment proceedings were held unsustainable, and the finding was in favour of the assessee.

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