https://www.taxtmi.com/caselaws?id=8412 Reassessment under section 147(a) of the Indian Income-tax Act, 1922 requires failure to disclose primary and material facts necessary for assessment; mere omission to state the inference to be drawn from facts already disclosed does not satisfy that condition. The assessee had placed the relevant orders and basic facts before the Income-tax Officer, enabling examination of whether the Bangalore concern was independent or merely a branch. As the alleged non-disclosure was only inferential and the additional factual notes were not the basis of the reopening belief, the precondition for jurisdiction under section 147(a) was not met and the reassessment notices under section 148 were invalid. en-us Thu, 25 Jun 1970 00:00:00 +0530 Wed, 15 Apr 2009 09:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8412 Reassessment under section 147(a) of the Indian Income-tax Act, 1922 requires failure to disclose primary and material facts necessary for assessment; mere omission to state the inference to be drawn from facts already disclosed does not satisfy that condition. The assessee had placed the relevant orders and basic facts before the Income-tax Officer, enabling examination of whether the Bangalore concern was independent or merely a branch. As the alleged non-disclosure was only inferential and the additional factual notes were not the basis of the reopening belief, the precondition for jurisdiction under section 147(a) was not met and the reassessment notices under section 148 were invalid. Case-Laws Income Tax Thu, 25 Jun 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8412