https://www.taxtmi.com/caselaws?id=20155 Reassessment was invalid where the assessee had disclosed all primary facts relating to shareholding, liquidation, receipt of shares and the bonus issue, because the duty of disclosure extends only to primary facts and not to legal inferences. The recorded reasons rested on a presumption that share premium necessarily represented accumulated profits, but they did not identify concrete material or a rational nexus supporting a belief of escaped income as deemed dividend. In the absence of any material omission by the assessee and without a live link between the reasons and the belief of escapement, the statutory conditions for reopening were not met, and the notice under section 148 was unsustainable. en-us Tue, 15 Jun 1993 00:00:00 +0530 Thu, 12 Nov 2009 11:33:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20155 Reassessment was invalid where the assessee had disclosed all primary facts relating to shareholding, liquidation, receipt of shares and the bonus issue, because the duty of disclosure extends only to primary facts and not to legal inferences. The recorded reasons rested on a presumption that share premium necessarily represented accumulated profits, but they did not identify concrete material or a rational nexus supporting a belief of escaped income as deemed dividend. In the absence of any material omission by the assessee and without a live link between the reasons and the belief of escapement, the statutory conditions for reopening were not met, and the notice under section 148 was unsustainable. Case-Laws Income Tax Tue, 15 Jun 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20155