https://www.taxtmi.com/caselaws?id=6490 Reassessment beyond the statutory time limit is valid only where escaped income is linked to the assessee's omission or failure to disclose fully and truly all primary facts necessary for assessment. The assessee's duty is limited to disclosure of primary facts; the assessing authority must draw the correct legal and factual inferences from those facts. Where depreciation particulars were already before the department, an error in applying the depreciation ceiling or a later change of opinion on the same material does not amount to nondisclosure by the assessee. On those facts, the reassessment notices were invalid because the escapement arose from departmental error, not from any failure of disclosure. en-us Tue, 16 Nov 1976 00:00:00 +0530 Thu, 30 Jun 2016 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6490 Reassessment beyond the statutory time limit is valid only where escaped income is linked to the assessee's omission or failure to disclose fully and truly all primary facts necessary for assessment. The assessee's duty is limited to disclosure of primary facts; the assessing authority must draw the correct legal and factual inferences from those facts. Where depreciation particulars were already before the department, an error in applying the depreciation ceiling or a later change of opinion on the same material does not amount to nondisclosure by the assessee. On those facts, the reassessment notices were invalid because the escapement arose from departmental error, not from any failure of disclosure. Case-Laws Income Tax Tue, 16 Nov 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6490