https://www.taxtmi.com/caselaws?id=29400 Reassessment under section 147(a) could not be sustained where the assessee had truly and fully disclosed all basic and material facts in the original assessment. The assessee is required to disclose facts, not the legal inferences to be drawn from them, and reopening cannot rest merely on a later different view of the same disclosed material. On the facts, no new basic fact emerged after the original return, and the finding of full disclosure was not shown to be perverse or unsupported by evidence. Reopening was therefore not justified and the issue was decided in favour of the assessee. en-us Mon, 22 Jun 1981 00:00:00 +0530 Fri, 12 Mar 2010 15:46:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29400 Reassessment under section 147(a) could not be sustained where the assessee had truly and fully disclosed all basic and material facts in the original assessment. The assessee is required to disclose facts, not the legal inferences to be drawn from them, and reopening cannot rest merely on a later different view of the same disclosed material. On the facts, no new basic fact emerged after the original return, and the finding of full disclosure was not shown to be perverse or unsupported by evidence. Reopening was therefore not justified and the issue was decided in favour of the assessee. Case-Laws Income Tax Mon, 22 Jun 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29400