Full disclosure and prior enquiry bar reopening under section 147(a) when later contrary findings arise on similar facts.

Reassessment under section 147(a) is not justified where the assessee has disclosed all primary facts, the original assessment was completed after enquiry, and the Assessing Officer accepted the claim on those facts. The assessee's duty is limited to full disclosure of material facts; it does not extend to drawing inferences or anticipating the officer's conclusions. A later contrary view on similar facts in proceedings for another year does not, by itself, provide a valid basis for reopening an assessment already made after due enquiry.

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Issues: Whether reassessment under section 147(a) was valid when the assessee had disclosed all primary facts in the original assessment and the original deduction had been allowed after enquiry, but a contrary finding on similar facts was later recorded for a subsequent assessment year.

Analysis: The assessee had furnished the relevant accounts, disclosed the payment and the payee, and the Assessing Officer had made detailed enquiry before accepting the claim in the original assessment. In such a situation, the duty of the assessee extended to full disclosure of material facts, not to the drawing of inferences or to pre-empting possible conclusions by the Assessing Officer. A later contrary finding in proceedings for another year could not, by itself, cure the absence of a valid basis for reopening where the original assessment had been completed after enquiry on the same primary facts.

Conclusion: Reopening under section 147(a) was not justified and was bad in law.

Final Conclusion: The assessee succeeded because the reassessment was held invalid for want of a permissible basis under the reopening provision after full disclosure and due enquiry in the original assessment.

Ratio Decidendi: Where the assessee has fully disclosed the primary facts and the Assessing Officer has made enquiry and accepted them in the original assessment, a subsequent contrary view on those facts in later proceedings does not, by itself, justify reopening under the reassessment provision.

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