https://www.taxtmi.com/caselaws?id=14986 Reassessment under s.148 beyond four years was challenged on the ground that the proviso to s.147 was not satisfied because there was no failure to disclose fully and truly all material facts regarding valuation of closing stock, including customs duty on imported raw materials. Applying SC authority that an assessee's duty is confined to full disclosure of primary facts and not to advising the AO on factual or legal inferences, the HC held that the relevant particulars of bonded imported raw materials and closing stock as on the year-end had been disclosed and examined earlier. Consequently, the statutory precondition for reopening was absent and the s.148 notice was held unlawful and quashed. en-us Tue, 16 May 2000 00:00:00 +0530 Sun, 04 Jan 2026 13:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14986 Reassessment under s.148 beyond four years was challenged on the ground that the proviso to s.147 was not satisfied because there was no failure to disclose fully and truly all material facts regarding valuation of closing stock, including customs duty on imported raw materials. Applying SC authority that an assessee's duty is confined to full disclosure of primary facts and not to advising the AO on factual or legal inferences, the HC held that the relevant particulars of bonded imported raw materials and closing stock as on the year-end had been disclosed and examined earlier. Consequently, the statutory precondition for reopening was absent and the s.148 notice was held unlawful and quashed. Case-Laws Income Tax Tue, 16 May 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14986