Non-disclosure of material facts justified reopening the assessment under section 147(a) for escapement of income.

Non-disclosure of material facts necessary for assessment was sufficient to confer jurisdiction to reopen the assessment under section 147(a). The assessee had withheld his share of credit in a joint account, and the earlier surrender of a different amount in the original assessment did not cover this undisclosed credit. On that basis, escapement of income was established, and reassessment proceedings were validly initiated.

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Issues: Whether reassessment proceedings under section 147(a) of the Income-tax Act, 1961 were validly initiated on the basis of non-disclosure of material facts.

Analysis: The assessee had kept back his share of credit in the joint account maintained in the books of Northern India Motor Parts Manufacturing Co. The earlier surrender of a different amount in the original assessment did not relate to this undisclosed credit. The non-disclosure of material facts necessary for assessment was sufficient to confer jurisdiction for reopening, and the resulting escapement of income justified initiation of reassessment proceedings.

Conclusion: The reassessment proceedings under section 147(a) were validly initiated.

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