Reassessment for nondisclosure fails where primary facts were fully disclosed and no failure to reveal material facts is shown.

Reassessment under section 147(a) was invalid because the assessee had disclosed the primary material facts, including the bungalow construction, expenditure, payment statements, bank accounts and sources of investment. The assessee was not required to state the inferences the assessing authority should draw, and omission of minute details such as quantity of materials used did not amount to failure to disclose fully and truly all material facts. The assessing authority could have made further inquiry or referred the matter for valuation but did not do so, and an already available survey report could not justify reopening for the later year. The additions in reassessment were therefore not sustainable.

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Issues: Whether the assessments could be reopened under section 147(a) of the Income-tax Act, 1961 on the ground of nondisclosure of material facts, and whether the additions made in the reassessment proceedings were sustainable.

Analysis: The assessee had disclosed the construction of the bungalow, the expenditure incurred in the relevant years, the statements showing payments for building materials, the bank accounts, and the sources of investment. Those disclosures constituted the primary facts necessary for assessment. The assessee was not required to indicate what inferences the assessing authority should draw from those facts, and mere failure to give minute details such as the quantity of materials used did not amount to failure to disclose fully and truly all material facts. The assessing authority could have made further inquiry or referred the matter for valuation, but did not do so. For the later assessment year, the survey report was already available when the original assessment was completed, so it could not furnish a valid basis for reopening.

Conclusion: The reopening under section 147(a) was invalid and the additions made in reassessment were not justified.

Ratio Decidendi: Reassessment under section 147(a) is permissible only when there is failure by the assessee to disclose primary material facts fully and truly; the assessee is not bound to draw or disclose the inferences that the assessing authority may derive from those facts.

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