https://www.taxtmi.com/caselaws?id=6445 Reassessment under sections 147 and 148 of the Income-tax Act is not valid where all primary facts were already before the assessing authority and there was no failure by the assessee to disclose fully and truly all material facts. The reopening machinery cannot be used to correct an assessing officer's own oversight or failure to draw the proper legal inference from material already on record. Where the alleged escapement of income arises from such oversight rather than nondisclosure by the assessee, the notice for reassessment and the resulting proceedings are liable to be quashed. en-us Thu, 01 May 1975 00:00:00 +0530 Tue, 24 Nov 2015 14:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6445 Reassessment under sections 147 and 148 of the Income-tax Act is not valid where all primary facts were already before the assessing authority and there was no failure by the assessee to disclose fully and truly all material facts. The reopening machinery cannot be used to correct an assessing officer's own oversight or failure to draw the proper legal inference from material already on record. Where the alleged escapement of income arises from such oversight rather than nondisclosure by the assessee, the notice for reassessment and the resulting proceedings are liable to be quashed. Case-Laws Income Tax Thu, 01 May 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6445