https://www.taxtmi.com/caselaws?id=7802 Section 34(1)(a) of the Indian Income-tax Act, 1922 permits reopening only where the assessee failed to disclose fully and truly all primary facts material to the original assessment; it does not extend to later inferences drawn from facts already disclosed. The assessments had proceeded on the credited amounts, the relevant statements had been recorded, and the later sale deed and enquiries about land value were only post-assessment materials that could suggest the credits were unreal. That kind of subsequent inference cannot amount to a jurisdictional non-disclosure under section 34(1)(a). The reopening notices were therefore invalid and without jurisdiction. en-us Mon, 09 Sep 1968 00:00:00 +0530 Thu, 19 Mar 2009 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7802 Section 34(1)(a) of the Indian Income-tax Act, 1922 permits reopening only where the assessee failed to disclose fully and truly all primary facts material to the original assessment; it does not extend to later inferences drawn from facts already disclosed. The assessments had proceeded on the credited amounts, the relevant statements had been recorded, and the later sale deed and enquiries about land value were only post-assessment materials that could suggest the credits were unreal. That kind of subsequent inference cannot amount to a jurisdictional non-disclosure under section 34(1)(a). The reopening notices were therefore invalid and without jurisdiction. Case-Laws Income Tax Mon, 09 Sep 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7802