https://www.taxtmi.com/caselaws?id=289898 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 requires escaped assessment to arise from the assessee's omission or failure to disclose fully and truly all primary material facts. Once those facts are disclosed, the assessee is not required to state the legal inference to be drawn from them. As the recorded reasons did not show any such failure and the reopening rested only on a later change in legal interpretation, the jurisdictional condition was not met and the notices were without jurisdiction. en-us Fri, 17 Feb 1961 00:00:00 +0530 Fri, 28 Aug 2020 18:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289898 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 requires escaped assessment to arise from the assessee's omission or failure to disclose fully and truly all primary material facts. Once those facts are disclosed, the assessee is not required to state the legal inference to be drawn from them. As the recorded reasons did not show any such failure and the reopening rested only on a later change in legal interpretation, the jurisdictional condition was not met and the notices were without jurisdiction. Case-Laws Income Tax Fri, 17 Feb 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289898