Full and true disclosure for reassessment depends on primary facts; non-disclosure upheld, validating reopening.

For reopening under Section 34(1)(a) of the Indian Income-tax Act, 1922, the assessee must disclose fully and truly all primary and material facts relevant to assessment, and mere production of books of account does not automatically discharge that duty. Whether disclosure was full and true depends on the nature of the facts and surrounding circumstances, and the Tribunal's finding on non-disclosure is ordinarily a finding of fact unless shown to be perverse or unsupported by evidence. On the facts found, the assessee had not drawn the Income-tax Officer's attention to material matters sufficient to bar reassessment, so the reassessment was held valid in favour of the Revenue.

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Issues: Whether the reassessment under Section 34(1)(a) of the Indian Income-tax Act, 1922 was valid on the ground that the assessee had failed to disclose fully and truly all material and relevant facts necessary for the assessment.

Analysis: The applicable principle is that an assessee must disclose fully and truly all material and relevant facts, and mere production of books or accounts does not automatically satisfy that obligation. Whether the facts disclosed in a particular case amount to such full disclosure depends on the nature of the facts and the surrounding circumstances. The Court also treated the Tribunal's finding on non-disclosure as a finding of fact, not open to interference in the absence of perversity, absence of evidence, or a conclusion no reasonable person could reach. On the facts found, the assessee had not drawn the Income-tax Officer's attention to matters of significance sufficient to negate the reassessment jurisdiction.

Conclusion: The reassessment was valid, and the question was answered in the affirmative in favour of the Revenue.

Ratio Decidendi: For purposes of reopening under Section 34(1)(a) of the Indian Income-tax Act, 1922, disclosure must extend to all primary and material facts relevant to the assessment, and whether such disclosure was full and true is ordinarily a question of fact unless the finding is shown to be perverse or unsupported by evidence.

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