https://www.taxtmi.com/caselaws?id=9302 Reopening of completed assessments was upheld because the Income-tax Officer had prima facie material indicating that the assessee had not fully and truly disclosed material facts, including evidence that alleged creditors were not genuine lenders and that the hundi transactions were part of a hawala arrangement. The court treated the matter as one of failure to disclose primary facts, so section 147(a) applied rather than section 147(b), and the reassessment was not barred by limitation on the assessee's case. The constitutional challenge to section 297(2)(d)(ii) also failed, the provision having been treated as valid and consistent with article 14. en-us Fri, 08 Dec 1972 00:00:00 +0530 Sun, 21 Jun 2009 17:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9302 Reopening of completed assessments was upheld because the Income-tax Officer had prima facie material indicating that the assessee had not fully and truly disclosed material facts, including evidence that alleged creditors were not genuine lenders and that the hundi transactions were part of a hawala arrangement. The court treated the matter as one of failure to disclose primary facts, so section 147(a) applied rather than section 147(b), and the reassessment was not barred by limitation on the assessee's case. The constitutional challenge to section 297(2)(d)(ii) also failed, the provision having been treated as valid and consistent with article 14. Case-Laws Income Tax Fri, 08 Dec 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9302