https://www.taxtmi.com/caselaws?id=9145 Reopening of assessment under section 147(a) depends on two conditions: the assessee must have failed to disclose fully and truly all material facts, and the Income-tax Officer must have recorded contemporaneous reasons showing a bona fide belief that income escaped assessment. Here, the omission of income in the relevant year amounted to non-disclosure, so the assessee could not resist reopening on that ground. However, the reassessment failed because the only recorded basis for initiation was the Commissioner's direction, with no contemporaneous record of the Officer's own requisite belief. Later reasons could not cure that defect, so the reassessment was without jurisdiction. en-us Fri, 09 Feb 1973 00:00:00 +0530 Fri, 23 Jan 2026 14:10:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9145 Reopening of assessment under section 147(a) depends on two conditions: the assessee must have failed to disclose fully and truly all material facts, and the Income-tax Officer must have recorded contemporaneous reasons showing a bona fide belief that income escaped assessment. Here, the omission of income in the relevant year amounted to non-disclosure, so the assessee could not resist reopening on that ground. However, the reassessment failed because the only recorded basis for initiation was the Commissioner's direction, with no contemporaneous record of the Officer's own requisite belief. Later reasons could not cure that defect, so the reassessment was without jurisdiction. Case-Laws Income Tax Fri, 09 Feb 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9145