https://www.taxtmi.com/caselaws?id=440423 Reopening of assessment under tax law turned on whether non disclosure justified issuance of notice. The court applied the reason to believe standard and reiterated that the assessee must fully disclose primary facts but need not predict legal inferences; drawing legal inference is the assessing officer's function. Because all material primary facts, including brought forward unabsorbed depreciation, were disclosed and considered in the original 143(3) assessment and figures were scrutinised, there was no omission to disclose and reopening under the provision was unwarranted. The result was decided for the assessee. en-us Fri, 14 Jul 2023 00:00:00 +0530 Wed, 11 Feb 2026 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440423 Reopening of assessment under tax law turned on whether non disclosure justified issuance of notice. The court applied the reason to believe standard and reiterated that the assessee must fully disclose primary facts but need not predict legal inferences; drawing legal inference is the assessing officer's function. Because all material primary facts, including brought forward unabsorbed depreciation, were disclosed and considered in the original 143(3) assessment and figures were scrutinised, there was no omission to disclose and reopening under the provision was unwarranted. The result was decided for the assessee. Case-Laws Income Tax Fri, 14 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440423