Reassessment reopening without failure to disclose cannot stand where the same material was already examined in the original assessment.

Reassessment under section 147(a) was not permissible where the assessee had already disclosed the relevant credit details and interest claim in the original assessment, and the assessing officer had examined that material. On those facts, there was no omission or failure to disclose material particulars fully and truly, so a later reopening could not be founded on the same material merely because a different inference was drawn. The reassessment notice under section 148 was therefore bad in law.

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Issues: Whether the reassessment notice under section 148 was valid when the assessee had already furnished the relevant details and the reopening was invoked under section 147(a).

Analysis: The assessee had disclosed the credit details and the interest claim during the original assessment, and the Income-tax Officer had verified and acted on that material. On those facts, the later reopening could not be justified as a case of omission or failure by the assessee to disclose material particulars fully and truly. A mere different inference from the same material did not confer jurisdiction to reopen under section 147(a).

Conclusion: The reassessment notice under section 148 was bad in law and the reopening under section 147(a) was not permissible.

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