https://www.taxtmi.com/caselaws?id=6427 Reassessment under section 147(a) requires a real failure by the assessee to disclose fully and truly all material facts necessary for assessment. The Court held that the later trust deeds relied on by the Revenue merely repeated facts already disclosed in the earlier deeds and original assessments, so their non-production did not amount to a material omission. A later change of view on the same material cannot justify reopening a completed assessment. The reassessment notice was therefore without jurisdiction and the Revenue's appeal failed. en-us Wed, 16 Oct 1974 00:00:00 +0530 Tue, 24 Nov 2015 14:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6427 Reassessment under section 147(a) requires a real failure by the assessee to disclose fully and truly all material facts necessary for assessment. The Court held that the later trust deeds relied on by the Revenue merely repeated facts already disclosed in the earlier deeds and original assessments, so their non-production did not amount to a material omission. A later change of view on the same material cannot justify reopening a completed assessment. The reassessment notice was therefore without jurisdiction and the Revenue's appeal failed. Case-Laws Income Tax Wed, 16 Oct 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6427