https://www.taxtmi.com/caselaws?id=37994 Reassessment under section 147(a) requires a reasonable belief that income escaped assessment because the assessee failed to disclose fully and truly all primary facts. Subsequent confessional statements by alleged creditors did not establish a specific nondisclosure by the assessee, especially where the books and hundis had been produced and examined during the original assessment. Later material that only supports a different view of the same facts cannot justify reopening. The Calcutta HC therefore held that the reassessment was not valid and that the original assessment could not be reopened on the material relied on by the revenue. en-us Fri, 12 May 1978 00:00:00 +0530 Fri, 02 Apr 2010 14:24:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37994 Reassessment under section 147(a) requires a reasonable belief that income escaped assessment because the assessee failed to disclose fully and truly all primary facts. Subsequent confessional statements by alleged creditors did not establish a specific nondisclosure by the assessee, especially where the books and hundis had been produced and examined during the original assessment. Later material that only supports a different view of the same facts cannot justify reopening. The Calcutta HC therefore held that the reassessment was not valid and that the original assessment could not be reopened on the material relied on by the revenue. Case-Laws Income Tax Fri, 12 May 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37994