https://www.taxtmi.com/caselaws?id=288936 Reassessment under section 34(1)(a) required a jurisdictional failure to file a return or a failure to make a full and true disclosure of primary facts. The assessee had filed a return through its agents on the basis of the non-resident status then accepted by the department, and had disclosed the relevant primary facts, including its status claim and income position. The assessee was not obliged to direct the officer on the legal inferences to be drawn from those facts. A later change of view by the assessing officer could not convert adequate disclosure into concealment or nondisclosure. The reopening notice was therefore without jurisdiction because the statutory conditions for reassessment were not met. en-us Thu, 03 Oct 1963 00:00:00 +0530 Mon, 06 Jul 2020 18:10:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=288936 Reassessment under section 34(1)(a) required a jurisdictional failure to file a return or a failure to make a full and true disclosure of primary facts. The assessee had filed a return through its agents on the basis of the non-resident status then accepted by the department, and had disclosed the relevant primary facts, including its status claim and income position. The assessee was not obliged to direct the officer on the legal inferences to be drawn from those facts. A later change of view by the assessing officer could not convert adequate disclosure into concealment or nondisclosure. The reopening notice was therefore without jurisdiction because the statutory conditions for reassessment were not met. Case-Laws Income Tax Thu, 03 Oct 1963 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=288936