https://www.taxtmi.com/caselaws?id=6628 Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 requires a bona fide reason to believe that income escaped assessment because the assessee omitted or failed to disclose fully and truly all material facts. Once primary facts are disclosed, the assessing authority must draw the correct legal inference, and a later change of opinion on the same materials does not justify reopening. On the facts noted, the alleged non-disclosure of the Eastern Bank account was not established, the assessee consistently maintained disclosure, and the prior assessments already reflected knowledge of the racing receipts. The reopening notices were therefore invalid for want of the statutory precondition. en-us Wed, 10 Jun 1964 00:00:00 +0530 Tue, 27 Jan 2009 17:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6628 Reassessment under section 34(1)(a) of the Indian Income-tax Act, 1922 requires a bona fide reason to believe that income escaped assessment because the assessee omitted or failed to disclose fully and truly all material facts. Once primary facts are disclosed, the assessing authority must draw the correct legal inference, and a later change of opinion on the same materials does not justify reopening. On the facts noted, the alleged non-disclosure of the Eastern Bank account was not established, the assessee consistently maintained disclosure, and the prior assessments already reflected knowledge of the racing receipts. The reopening notices were therefore invalid for want of the statutory precondition. Case-Laws Income Tax Wed, 10 Jun 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6628