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    <title>1971 (1) TMI 6 - Supreme Court</title>
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    <description>Reassessment under section 34(1)(a) of the Income-tax Act, 1922 cannot be initiated where the assessee has fully and truly disclosed all primary facts necessary for assessment. The assessee had disclosed its non-resident status, its Porbandar business, the Bombay bank account used for receipt and transfer of sale proceeds, and the interest income from the Bombay firm on which tax had been deducted at the maximum rate. On those facts, the Income-tax Officer was already aware of the material position, and the officer could not require the assessee to draw legal inferences or explain the legal effect of the disclosed facts. Reassessment was therefore held invalid because there was no failure to disclose material facts.</description>
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    <pubDate>Thu, 21 Jan 1971 00:00:00 +0530</pubDate>
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      <title>1971 (1) TMI 6 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6232</link>
      <description>Reassessment under section 34(1)(a) of the Income-tax Act, 1922 cannot be initiated where the assessee has fully and truly disclosed all primary facts necessary for assessment. The assessee had disclosed its non-resident status, its Porbandar business, the Bombay bank account used for receipt and transfer of sale proceeds, and the interest income from the Bombay firm on which tax had been deducted at the maximum rate. On those facts, the Income-tax Officer was already aware of the material position, and the officer could not require the assessee to draw legal inferences or explain the legal effect of the disclosed facts. Reassessment was therefore held invalid because there was no failure to disclose material facts.</description>
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      <pubDate>Thu, 21 Jan 1971 00:00:00 +0530</pubDate>
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