https://www.taxtmi.com/caselaws?id=6236 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 requires omission or failure to disclose fully and truly all material facts necessary for assessment. Disclosure of primary facts satisfies that obligation; the assessee is not required to point out the inference the Income-tax Officer should draw from them, including whether a transaction is sham. Production of books and documents that would enable the true nature of the transaction to be worked out does not by itself establish nondisclosure where the relevant facts were already placed before the assessing authority. On the facts disclosed, reopening was not justified. en-us Thu, 21 Jan 1971 00:00:00 +0530 Thu, 01 Oct 2015 18:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6236 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 requires omission or failure to disclose fully and truly all material facts necessary for assessment. Disclosure of primary facts satisfies that obligation; the assessee is not required to point out the inference the Income-tax Officer should draw from them, including whether a transaction is sham. Production of books and documents that would enable the true nature of the transaction to be worked out does not by itself establish nondisclosure where the relevant facts were already placed before the assessing authority. On the facts disclosed, reopening was not justified. Case-Laws Income Tax Thu, 21 Jan 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6236