https://www.taxtmi.com/caselaws?id=8292 Reassessment under section 147(a) is valid only where the assessee failed to disclose fully and truly all primary material facts and the assessing authority had a bona fide reason to believe, based on that failure, that income had escaped assessment. Once the primary facts are disclosed, the assessee's duty ends, and the officer must draw the proper factual and legal inferences. A reopening based only on a later change of opinion, or on suspicion over the same disclosed material, is not permissible. On the facts discussed, the relevant material had been disclosed at the original assessment stage, so the reassessment was not valid. en-us Tue, 06 Oct 1970 00:00:00 +0530 Thu, 09 Apr 2009 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8292 Reassessment under section 147(a) is valid only where the assessee failed to disclose fully and truly all primary material facts and the assessing authority had a bona fide reason to believe, based on that failure, that income had escaped assessment. Once the primary facts are disclosed, the assessee's duty ends, and the officer must draw the proper factual and legal inferences. A reopening based only on a later change of opinion, or on suspicion over the same disclosed material, is not permissible. On the facts discussed, the relevant material had been disclosed at the original assessment stage, so the reassessment was not valid. Case-Laws Income Tax Tue, 06 Oct 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8292