https://www.taxtmi.com/caselaws?id=21923 Reassessment under section 147(a) requires escapement of income to result from the assessee's failure to disclose primary facts fully and truly; the duty does not extend to drawing inferences from those facts. Where the earlier allowance of initial depreciation was already on record and the Income-tax Officer had applied his own mind in the original assessment, no omission by the assessee can be inferred merely because the officer later took a different view. On those facts, the reopening was invalid and the reference was answered in favour of the assessee. en-us Thu, 25 Apr 1991 00:00:00 +0530 Fri, 04 Dec 2009 12:19:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21923 Reassessment under section 147(a) requires escapement of income to result from the assessee's failure to disclose primary facts fully and truly; the duty does not extend to drawing inferences from those facts. Where the earlier allowance of initial depreciation was already on record and the Income-tax Officer had applied his own mind in the original assessment, no omission by the assessee can be inferred merely because the officer later took a different view. On those facts, the reopening was invalid and the reference was answered in favour of the assessee. Case-Laws Income Tax Thu, 25 Apr 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21923