https://www.taxtmi.com/caselaws?id=6684 An assessee satisfies the disclosure obligation by placing all primary facts material to assessment before the tax authority; it is not required to state the correct legal inference or the proper basis of chargeability. Once those primary facts are disclosed, the authority must draw the necessary legal conclusions. On the stated facts, disclosure of the relevant bank account and sale proceeds in British India was sufficient, and the alleged omission of another account did not amount to suppression of a primary material fact. Any escapement arose from the Income-tax Officer's erroneous view on chargeability, not from failure to disclose. The condition precedent for reopening under section 34(1)(a) was therefore not met, and the reassessment notices and reassessments were invalid. en-us Fri, 11 Feb 1966 00:00:00 +0530 Sun, 01 Feb 2009 05:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6684 An assessee satisfies the disclosure obligation by placing all primary facts material to assessment before the tax authority; it is not required to state the correct legal inference or the proper basis of chargeability. Once those primary facts are disclosed, the authority must draw the necessary legal conclusions. On the stated facts, disclosure of the relevant bank account and sale proceeds in British India was sufficient, and the alleged omission of another account did not amount to suppression of a primary material fact. Any escapement arose from the Income-tax Officer's erroneous view on chargeability, not from failure to disclose. The condition precedent for reopening under section 34(1)(a) was therefore not met, and the reassessment notices and reassessments were invalid. Case-Laws Income Tax Fri, 11 Feb 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6684