https://www.taxtmi.com/caselaws?id=5562 Reopening under section 34(1)(a) failed where the assessee had already disclosed the lease deed and other primary facts, because there was no failure to disclose fully and truly all material facts and no duty to point out the legal inference. The reassessments for 1950-51 to 1956-57 were therefore invalid under clause (a). By contrast, reassessments for 1954-55 to 1956-57 were sustained under section 34(1)(b), since information already on record, including assessment material, could support reopening within the statutory period. A levy of penal interest under section 18A could be challenged in an appeal against the assessment order, not by a separate appeal. en-us Wed, 05 Feb 1997 00:00:00 +0530 Mon, 13 Oct 2025 19:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5562 Reopening under section 34(1)(a) failed where the assessee had already disclosed the lease deed and other primary facts, because there was no failure to disclose fully and truly all material facts and no duty to point out the legal inference. The reassessments for 1950-51 to 1956-57 were therefore invalid under clause (a). By contrast, reassessments for 1954-55 to 1956-57 were sustained under section 34(1)(b), since information already on record, including assessment material, could support reopening within the statutory period. A levy of penal interest under section 18A could be challenged in an appeal against the assessment order, not by a separate appeal. Case-Laws Income Tax Wed, 05 Feb 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5562