https://www.taxtmi.com/caselaws?id=28809 Reopening under section 147(a) requires a reasonable belief that income escaped assessment because the assessee failed to disclose material facts fully and truly. Where the primary facts, including the articles of association, were available during the original assessment and no omitted facts were identified, that condition is not met. Contributions to a recognised provident fund qualify for deduction under section 36(1)(iv) when the relevant facts are disclosed. A contribution is not rendered non-deductible merely because it derogates from the company's articles of association, which govern internal affairs rather than the legality of third-party transactions. en-us Thu, 05 Aug 1982 00:00:00 +0530 Thu, 25 Feb 2010 18:26:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28809 Reopening under section 147(a) requires a reasonable belief that income escaped assessment because the assessee failed to disclose material facts fully and truly. Where the primary facts, including the articles of association, were available during the original assessment and no omitted facts were identified, that condition is not met. Contributions to a recognised provident fund qualify for deduction under section 36(1)(iv) when the relevant facts are disclosed. A contribution is not rendered non-deductible merely because it derogates from the company's articles of association, which govern internal affairs rather than the legality of third-party transactions. Case-Laws Income Tax Thu, 05 Aug 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28809