https://www.taxtmi.com/caselaws?id=66007 Non-disclosure of a collateral reconveyance agreement did not justify reopening under section 147(a) because the purchase, lease-back arrangement and lease rent had already been disclosed, and the agreement was not a primary fact material to the original assessment. Reassessment for the first two years was therefore invalid. Reopening under section 147(b) also failed because it rested on an audit party's legal view that lease rent was really interest and the transaction was a mortgage by conditional sale; an audit opinion on a point of law is not "information" for that purpose. The reassessment for the later year was therefore invalid, and the revenue's challenge failed in full. en-us Thu, 26 Jun 1986 00:00:00 +0530 Sat, 19 Feb 2011 17:53:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66007 Non-disclosure of a collateral reconveyance agreement did not justify reopening under section 147(a) because the purchase, lease-back arrangement and lease rent had already been disclosed, and the agreement was not a primary fact material to the original assessment. Reassessment for the first two years was therefore invalid. Reopening under section 147(b) also failed because it rested on an audit party's legal view that lease rent was really interest and the transaction was a mortgage by conditional sale; an audit opinion on a point of law is not "information" for that purpose. The reassessment for the later year was therefore invalid, and the revenue's challenge failed in full. Case-Laws Income Tax Thu, 26 Jun 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66007