https://www.taxtmi.com/caselaws?id=36001 Reassessment under sections 147 and 148 cannot be sustained where the assessee has fully and truly disclosed all primary facts, including the ancestral nature of the land, its sale, and the income received; the assessing authority must draw its own inference from disclosed facts, and reopening on a later different inference amounts to a change of opinion. The notices also failed on the alternative ground that they were not shown to be addressed to an association of persons, and the character of the notice could not be recast later to support reopening. The impugned reassessment notices and consequential proceedings were quashed. en-us Tue, 17 Feb 1981 00:00:00 +0530 Thu, 18 Mar 2010 17:34:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36001 Reassessment under sections 147 and 148 cannot be sustained where the assessee has fully and truly disclosed all primary facts, including the ancestral nature of the land, its sale, and the income received; the assessing authority must draw its own inference from disclosed facts, and reopening on a later different inference amounts to a change of opinion. The notices also failed on the alternative ground that they were not shown to be addressed to an association of persons, and the character of the notice could not be recast later to support reopening. The impugned reassessment notices and consequential proceedings were quashed. Case-Laws Income Tax Tue, 17 Feb 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36001