https://www.taxtmi.com/caselaws?id=8799 Reassessment under section 147(a) is valid only where the Income-tax Officer has reason to believe that income escaped assessment because the assessee failed to disclose fully and truly all material primary facts; a mere change of opinion is insufficient. On the materials discussed, reopening was sustained only for assessment years supported by fresh and relevant information indicating possible escapement, and was invalid where it relied on matters already examined or failed to meet the statutory threshold, including the limit under section 149(a)(ii). The later conduct of the founder or alleged misuse of trust funds could not by itself justify reopening the question whether the trust was genuine, as such conduct did not undo the original dedication. en-us Thu, 21 Dec 1972 00:00:00 +0530 Thu, 15 Jan 2026 15:47:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8799 Reassessment under section 147(a) is valid only where the Income-tax Officer has reason to believe that income escaped assessment because the assessee failed to disclose fully and truly all material primary facts; a mere change of opinion is insufficient. On the materials discussed, reopening was sustained only for assessment years supported by fresh and relevant information indicating possible escapement, and was invalid where it relied on matters already examined or failed to meet the statutory threshold, including the limit under section 149(a)(ii). The later conduct of the founder or alleged misuse of trust funds could not by itself justify reopening the question whether the trust was genuine, as such conduct did not undo the original dedication. Case-Laws Income Tax Thu, 21 Dec 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8799