Primary facts disclosure defeats reassessment where reopening is based on issues the assessing officer should have examined.

Reassessment notices under sections 147 and 148 were held invalid where the assessee had already disclosed the primary facts supporting its claims for deduction under section 80-I and development rebate under section 33. The court noted that the assessee had placed before the assessing officer the basic material, including the nature of manufacture and the basis for relief, and any further scrutiny of eligibility was for the assessing officer to undertake. Because there was no failure to fully and truly disclose all material facts necessary for assessment, the jurisdictional basis for reopening was absent and the notices were liable to be quashed in favour of the assessee.

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Issues: Whether the reassessment notices issued under sections 147 and 148 of the Income-tax Act, 1961 were valid when the assessee had disclosed the primary facts relating to its claim for deduction under section 80-1 and development rebate under section 33.

Analysis: The assessee had placed before the assessing officer the basic facts necessary for consideration of its claim, including the nature of its manufacture and the basis on which relief was sought. Once the primary facts were disclosed, any further doubt as to eligibility required inquiry by the assessing officer. The material did not support a finding that there had been a failure to disclose fully and truly all material facts necessary for assessment. On that footing, the jurisdictional foundation for reopening the assessment was absent.

Conclusion: The reassessment action under sections 147 and 148 was invalid, and the notices were liable to be quashed, in favour of the assessee.

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