https://www.taxtmi.com/caselaws?id=289405 A reassessment notice was held invalid where the assessee had already placed all primary facts before the Income-tax Officer at the original assessment. The registered partition deed, the claim under section 25A, and the ownership and source of the properties were disclosed, and the assessment order itself showed that the officer had considered the partial partition. On that basis, the omission to return property income did not amount to failure to disclose material facts, because the assessee was only required to disclose primary facts and not the legal inference. The later reply could not change that position. The notice under section 147(a) was therefore without jurisdiction and quashed. en-us Thu, 20 Aug 1964 00:00:00 +0530 Wed, 29 Jul 2020 12:57:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289405 A reassessment notice was held invalid where the assessee had already placed all primary facts before the Income-tax Officer at the original assessment. The registered partition deed, the claim under section 25A, and the ownership and source of the properties were disclosed, and the assessment order itself showed that the officer had considered the partial partition. On that basis, the omission to return property income did not amount to failure to disclose material facts, because the assessee was only required to disclose primary facts and not the legal inference. The later reply could not change that position. The notice under section 147(a) was therefore without jurisdiction and quashed. Case-Laws Income Tax Thu, 20 Aug 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289405