https://www.taxtmi.com/caselaws?id=286518 Reassessment jurisdiction under section 34(1)(a) of the Income-tax Act, 1922 arose only if the Income-tax Officer had reasonable grounds to believe both that income had been under-assessed and that the under-assessment resulted from failure to disclose fully and truly all material facts. That statutory belief could not rest on suspicion or on a misreading of incomplete records when the surrounding correspondence and assessment materials showed disclosure of the Punjab outstandings. The records negatived any inference that the assessee had concealed those outstandings or misrepresented its capital. The Bombay HC therefore held that the reassessment notices were issued without jurisdiction and quashed them. en-us Wed, 17 Jun 1964 00:00:00 +0530 Mon, 02 Mar 2020 11:00:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286518 Reassessment jurisdiction under section 34(1)(a) of the Income-tax Act, 1922 arose only if the Income-tax Officer had reasonable grounds to believe both that income had been under-assessed and that the under-assessment resulted from failure to disclose fully and truly all material facts. That statutory belief could not rest on suspicion or on a misreading of incomplete records when the surrounding correspondence and assessment materials showed disclosure of the Punjab outstandings. The records negatived any inference that the assessee had concealed those outstandings or misrepresented its capital. The Bombay HC therefore held that the reassessment notices were issued without jurisdiction and quashed them. Case-Laws Income Tax Wed, 17 Jun 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286518