https://www.taxtmi.com/caselaws?id=71543 Reassessment under section 147(a) was upheld because the original return did not fully and truly disclose primary facts material to assessment, including the sale of the sub-plot with the farm house, the basis and extent of land conversion into stock-in-trade, the consideration received, and the computation of capital gains or business profits. A vague note annexed to the return was insufficient to meet the statutory duty of disclosure, and later reliance on wealth-tax records, a section 230A certificate, and Chapter XXA proceedings could not cure the omission because those materials were not before the Assessing Officer in the original income-tax proceedings. The Tribunal also held that the case involved no mere change of opinion, as no prior opinion on these matters had been formed. en-us Mon, 05 Feb 1996 00:00:00 +0530 Sat, 22 Jun 2013 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71543 Reassessment under section 147(a) was upheld because the original return did not fully and truly disclose primary facts material to assessment, including the sale of the sub-plot with the farm house, the basis and extent of land conversion into stock-in-trade, the consideration received, and the computation of capital gains or business profits. A vague note annexed to the return was insufficient to meet the statutory duty of disclosure, and later reliance on wealth-tax records, a section 230A certificate, and Chapter XXA proceedings could not cure the omission because those materials were not before the Assessing Officer in the original income-tax proceedings. The Tribunal also held that the case involved no mere change of opinion, as no prior opinion on these matters had been formed. Case-Laws Income Tax Mon, 05 Feb 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71543