https://www.taxtmi.com/caselaws?id=29530 Section 147(a) requires escapement of income to result from the assessee's omission or failure to disclose fully and truly all material facts necessary for assessment. Where the assessee had disclosed the relevant facts and the reopening was triggered only by a later sale of machinery, that subsequent event could not retrospectively create the jurisdictional basis for reassessment. The commentary also notes that, if the Revenue sought withdrawal of development rebate because of later sale, the statute provided a specific remedy under section 35(11) of the 1922 Act rather than reassessment under section 147(a). en-us Fri, 28 Aug 1981 00:00:00 +0530 Sat, 13 Mar 2010 15:50:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29530 Section 147(a) requires escapement of income to result from the assessee's omission or failure to disclose fully and truly all material facts necessary for assessment. Where the assessee had disclosed the relevant facts and the reopening was triggered only by a later sale of machinery, that subsequent event could not retrospectively create the jurisdictional basis for reassessment. The commentary also notes that, if the Revenue sought withdrawal of development rebate because of later sale, the statute provided a specific remedy under section 35(11) of the 1922 Act rather than reassessment under section 147(a). Case-Laws Income Tax Fri, 28 Aug 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29530