https://www.taxtmi.com/caselaws?id=5926 The SC upheld reassessment proceedings under section 147(a) of the Income-tax Act, 1961, finding that the assessee failed to disclose material facts regarding the composition of construction work for depreciation calculation purposes. The assessee had not provided details distinguishing between earth work and masonry work portions, which was material for determining correct depreciation allowances. The court held that omission to disclose material facts, whether deliberate or inadvertent, provides sufficient jurisdiction for reopening assessment if there are primary facts suggesting non-disclosure that could lead to income escapement. The HC correctly declined to call for a statement of case as this was a question of fact, not law. Appeals dismissed. en-us Wed, 12 Mar 1986 00:00:00 +0530 Sat, 14 Jun 2025 13:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5926 The SC upheld reassessment proceedings under section 147(a) of the Income-tax Act, 1961, finding that the assessee failed to disclose material facts regarding the composition of construction work for depreciation calculation purposes. The assessee had not provided details distinguishing between earth work and masonry work portions, which was material for determining correct depreciation allowances. The court held that omission to disclose material facts, whether deliberate or inadvertent, provides sufficient jurisdiction for reopening assessment if there are primary facts suggesting non-disclosure that could lead to income escapement. The HC correctly declined to call for a statement of case as this was a question of fact, not law. Appeals dismissed. Case-Laws Income Tax Wed, 12 Mar 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5926