https://www.taxtmi.com/caselaws?id=5929 Reassessment under section 147(a) requires the taxing authority to have reason to believe both that income escaped assessment and that the escapement resulted from the assessee's failure to disclose fully and truly all primary and material facts. The assessee had disclosed the nature of the London management charges, the allocation basis, and the work attributed to the London office, so the original assessments were made on that material. A later auditor's certificate could not by itself establish nondisclosure of primary facts; at most it supplied a new inference or opinion. The Court reiterated that the assessee must disclose primary facts, not draw inferences for the department, and that reopening cannot rest on mere suspicion. The reassessment notices were therefore invalid. en-us Thu, 08 May 1986 00:00:00 +0530 Thu, 30 Oct 2025 12:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5929 Reassessment under section 147(a) requires the taxing authority to have reason to believe both that income escaped assessment and that the escapement resulted from the assessee's failure to disclose fully and truly all primary and material facts. The assessee had disclosed the nature of the London management charges, the allocation basis, and the work attributed to the London office, so the original assessments were made on that material. A later auditor's certificate could not by itself establish nondisclosure of primary facts; at most it supplied a new inference or opinion. The Court reiterated that the assessee must disclose primary facts, not draw inferences for the department, and that reopening cannot rest on mere suspicion. The reassessment notices were therefore invalid. Case-Laws Income Tax Thu, 08 May 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5929