https://www.taxtmi.com/caselaws?id=7677 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 is valid only where the taxing authority has reason to believe that income escaped assessment because the assessee failed to disclose fully and truly all primary facts necessary for assessment. The assessee's duty extends to disclosure of primary facts, while drawing inferences from those facts remains the function of the assessing authority. On the stated analysis, where the relevant capital receipt, statements and facts showing accrual of interest had been disclosed, reopening could not rest on a mere change of opinion or suspicion. Once a reassessment is validly reopened, however, it proceeds de novo and other escaped items of income may also be examined. en-us Thu, 14 Aug 1969 00:00:00 +0530 Tue, 17 Mar 2009 15:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7677 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 is valid only where the taxing authority has reason to believe that income escaped assessment because the assessee failed to disclose fully and truly all primary facts necessary for assessment. The assessee's duty extends to disclosure of primary facts, while drawing inferences from those facts remains the function of the assessing authority. On the stated analysis, where the relevant capital receipt, statements and facts showing accrual of interest had been disclosed, reopening could not rest on a mere change of opinion or suspicion. Once a reassessment is validly reopened, however, it proceeds de novo and other escaped items of income may also be examined. Case-Laws Income Tax Thu, 14 Aug 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7677