https://www.taxtmi.com/caselaws?id=7943 An assessee satisfies the duty of disclosure under section 147(a) by placing all primary facts before the assessing authority; it is not obliged to supply the legal inference that the revenue should draw from those facts. Here, the assessee disclosed the commission claim and supporting books of account, so whether the payment was allowable required investigation by the Income-tax Officer. The failure to volunteer that the deduction was inadmissible was not a failure to disclose material facts. The Calcutta HC therefore held the reassessment notices under section 147(a) invalid and quashed the reassessment proceedings. en-us Thu, 18 Dec 1969 00:00:00 +0530 Tue, 24 Mar 2009 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7943 An assessee satisfies the duty of disclosure under section 147(a) by placing all primary facts before the assessing authority; it is not obliged to supply the legal inference that the revenue should draw from those facts. Here, the assessee disclosed the commission claim and supporting books of account, so whether the payment was allowable required investigation by the Income-tax Officer. The failure to volunteer that the deduction was inadmissible was not a failure to disclose material facts. The Calcutta HC therefore held the reassessment notices under section 147(a) invalid and quashed the reassessment proceedings. Case-Laws Income Tax Thu, 18 Dec 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7943