https://www.taxtmi.com/caselaws?id=8458 Reassessment under section 147(a) was upheld because the assessee failed to disclose a primary material fact, namely the actual date of sale of a capital asset. The disclosure of cost, written down value, and sale price was insufficient, as the date of transfer was essential to determine whether capital gains were taxable under the relevant cut-off date. The omission was treated as a failure to make full and true disclosure of all material facts necessary for assessment, and the resulting escapement of income sustained jurisdiction for reopening. The legal principle applied is that non-disclosure of a material primary fact, rather than a mere legal inference, is enough to justify reassessment. en-us Fri, 03 Sep 1971 00:00:00 +0530 Wed, 15 Apr 2009 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8458 Reassessment under section 147(a) was upheld because the assessee failed to disclose a primary material fact, namely the actual date of sale of a capital asset. The disclosure of cost, written down value, and sale price was insufficient, as the date of transfer was essential to determine whether capital gains were taxable under the relevant cut-off date. The omission was treated as a failure to make full and true disclosure of all material facts necessary for assessment, and the resulting escapement of income sustained jurisdiction for reopening. The legal principle applied is that non-disclosure of a material primary fact, rather than a mere legal inference, is enough to justify reassessment. Case-Laws Income Tax Fri, 03 Sep 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8458