Reassessment after four years may proceed where a taxpayer...

Reassessment after four years may proceed where a taxpayer credits a waived retired partner's capital balance but claims its exclusion from taxable income without disclosing supporting facts or the basis of non-taxability. The material states that such omission can amount to failure of full and true disclosure, and recorded reasons need only show a live link to a prima facie belief of escaped income; reassessment was sustained. On taxability, the taxpayer must substantiate the account composition, conversion to unsecured loan, retirement arrangement and waiver, while the assessing authority must identify the charging provision and give reasons. The addition was remanded for de novo, reasoned determination.