Reassessment notice invalid where full disclosure was made in original assessment and statutory reopening was not met.

Reassessment under the Income-tax Act cannot be validly initiated unless the record shows that the assessee failed to disclose fully and truly all material facts necessary for assessment. Where the bank pass books and related account materials were produced in the original assessment and that position was not controverted by any affidavit from the assessing officer, the alleged non-disclosure cannot be attributed to the assessee. The statutory precondition for reopening was therefore not satisfied, so the reassessment notice lacked legal foundation and the proceedings based on it were quashed as without jurisdiction.

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Issues: Whether the reassessment notice under section 148 of the Income-tax Act, 1961, was valid when the assessee had already produced the relevant bank pass books and account materials during the original assessment proceedings.

Analysis: The relevant question was whether there had been any omission or failure by the assessee to disclose fully and truly all material facts necessary for assessment. The material before the Court showed that the bank pass books had in fact been produced during the original assessment, and that assertion was not controverted by any affidavit from the assessing officer. On that basis, the Court held that the alleged non-disclosure could not be attributed to the assessee. Since the statutory condition for invoking reassessment was not satisfied, the reopening lacked legal foundation.

Conclusion: The reassessment notice was without jurisdiction and was quashed, along with any assessment made in pursuance of it.

Final Conclusion: The assessee succeeded in challenging the reopening, and the reassessment proceedings based on the impugned notice were set aside.

Ratio Decidendi: Reassessment is impermissible unless the statutory condition of failure by the assessee to disclose fully and truly all material facts necessary for assessment is established on the record.

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