https://www.taxtmi.com/caselaws?id=9079 Reassessment under section 34(1)(a) is sustainable only where income escaped assessment because the assessee failed to disclose fully and truly all material primary facts; the assessee is not required to supply the inference the department may later draw from those facts. Where all primary facts were already before the original assessing authority, a later change of opinion or fresh inference cannot justify reopening. On the facts, the transaction and receipt were already disclosed, and the later information did not establish any omission by the assessee, so the reopening notice was invalid. en-us Fri, 22 Dec 1972 00:00:00 +0530 Fri, 19 Jun 2009 11:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9079 Reassessment under section 34(1)(a) is sustainable only where income escaped assessment because the assessee failed to disclose fully and truly all material primary facts; the assessee is not required to supply the inference the department may later draw from those facts. Where all primary facts were already before the original assessing authority, a later change of opinion or fresh inference cannot justify reopening. On the facts, the transaction and receipt were already disclosed, and the later information did not establish any omission by the assessee, so the reopening notice was invalid. Case-Laws Income Tax Fri, 22 Dec 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9079