https://www.taxtmi.com/caselaws?id=219770 The High Court dismissed the Revenue's appeals, upholding the lower authorities' decisions that the reassessment proceedings were invalid. The Court found that the Assessing Officer failed to satisfy the jurisdictional pre-condition for issuing notices under Section 147/148 of the Income Tax Act. Additionally, it was determined that the assessee had fully disclosed all material facts during the original assessment, rendering the reassessment unwarranted. The Court emphasized that the Assessing Officer's duty is to draw conclusions based on disclosed primary facts and ruled in favor of the assessee, citing the principle that the assessee is not obligated to communicate inferences drawn from primary facts. en-us Tue, 11 Dec 2012 00:00:00 +0530 Mon, 24 Dec 2012 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219770 The High Court dismissed the Revenue's appeals, upholding the lower authorities' decisions that the reassessment proceedings were invalid. The Court found that the Assessing Officer failed to satisfy the jurisdictional pre-condition for issuing notices under Section 147/148 of the Income Tax Act. Additionally, it was determined that the assessee had fully disclosed all material facts during the original assessment, rendering the reassessment unwarranted. The Court emphasized that the Assessing Officer's duty is to draw conclusions based on disclosed primary facts and ruled in favor of the assessee, citing the principle that the assessee is not obligated to communicate inferences drawn from primary facts. Case-Laws Income Tax Tue, 11 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219770