Reopening assessments under section 147 is not justified solely by higher advance tax declarations; concealed income remains assessable.

Reopening assessments under section 147 cannot be founded solely on a taxpayer's declaration of a much higher income for advance tax; established judicial principles must guide any reopening or roving inquiries. A higher advance tax estimate cannot be offset against income concealed in an earlier year, which remains assessable in that year; voluntary disclosure and application for relief from penalty and interest are the appropriate taxpayer remedies.

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