https://www.taxtmi.com/caselaws?id=191006 Non-disclosure of a primary material fact, such as a transaction bearing directly on under-assessment, justified reopening under section 34(1)(a) of the Income-tax Act, 1922; the mere use of the word "information" in the reassessment order did not change the jurisdictional basis or attract section 34(1)(b). Once reasonable grounds existed to believe that a material fact had not been fully and truly disclosed, the reassessment was within jurisdiction and not time-barred on the basis contended. In advisory reference jurisdiction, the High Court could not reappraise evidence or disturb the Tribunal's findings of fact unless a specific question that those findings were without evidence or perverse had been properly referred, so the factual findings stood. en-us Fri, 10 Jan 1964 00:00:00 +0530 Thu, 16 Mar 2017 18:28:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191006 Non-disclosure of a primary material fact, such as a transaction bearing directly on under-assessment, justified reopening under section 34(1)(a) of the Income-tax Act, 1922; the mere use of the word "information" in the reassessment order did not change the jurisdictional basis or attract section 34(1)(b). Once reasonable grounds existed to believe that a material fact had not been fully and truly disclosed, the reassessment was within jurisdiction and not time-barred on the basis contended. In advisory reference jurisdiction, the High Court could not reappraise evidence or disturb the Tribunal's findings of fact unless a specific question that those findings were without evidence or perverse had been properly referred, so the factual findings stood. Case-Laws Income Tax Fri, 10 Jan 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191006