Reassessment for nondisclosure only: change of opinion or suspicion cannot justify reopening when primary facts were already disclosed.

Reassessment under section 147(a) is valid only where the assessee failed to disclose fully and truly all primary material facts and the assessing authority had a bona fide reason to believe, based on that failure, that income had escaped assessment. Once the primary facts are disclosed, the assessee's duty ends, and the officer must draw the proper factual and legal inferences. A reopening based only on a later change of opinion, or on suspicion over the same disclosed material, is not permissible. On the facts discussed, the relevant material had been disclosed at the original assessment stage, so the reassessment was not valid.

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Issues: Whether reassessment proceedings under section 147(a) of the Income-tax Act, 1961 were valid on the facts of the case.

Analysis: Reopening under section 147(a) depends on the existence of reason to believe that income had escaped assessment because of the assessee's omission or failure to disclose fully and truly all primary material facts. Once the primary facts are disclosed, the assessee's duty ends and it is for the assessing authority to draw factual and legal inferences. If the original assessment proceeded on the same disclosed facts and the reassessment is initiated only because a later officer draws a different inference, the case is one of change of opinion and not of nondisclosure. On the facts relating to the amounts in question, the material facts had been disclosed at the original assessment stage and the reassessment was founded on a different inference or, at best, mere suspicion.

Conclusion: The reassessment proceedings were not valid.

Ratio Decidendi: Reassessment under section 147(a) is permissible only where the assessee failed to disclose primary material facts and the Income-tax Officer had a bona fide reason to believe, founded on such failure, that income had escaped assessment; a mere change of opinion or suspicion cannot confer jurisdiction to reopen.

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