https://www.taxtmi.com/caselaws?id=26699 In reassessment proceedings, the court held that the Revenue was not required as a general rule to produce the recorded reasons for sanction where the reassessment order itself disclosed the basis of reopening. It further held that the assessee's duty of full and true disclosure extends to primary facts material to assessment, including the company's balance-sheet and accumulated profits when loan receipts may attract deemed-dividend treatment. Because those facts were not furnished, the assessing officer lacked the primary material needed to decide applicability of the provision, and reopening was validly initiated. The reassessment was upheld as within jurisdiction, with the merits remitted to the Tribunal. en-us Tue, 10 Sep 1985 00:00:00 +0530 Sat, 06 Feb 2010 18:27:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26699 In reassessment proceedings, the court held that the Revenue was not required as a general rule to produce the recorded reasons for sanction where the reassessment order itself disclosed the basis of reopening. It further held that the assessee's duty of full and true disclosure extends to primary facts material to assessment, including the company's balance-sheet and accumulated profits when loan receipts may attract deemed-dividend treatment. Because those facts were not furnished, the assessing officer lacked the primary material needed to decide applicability of the provision, and reopening was validly initiated. The reassessment was upheld as within jurisdiction, with the merits remitted to the Tribunal. Case-Laws Income Tax Tue, 10 Sep 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26699