https://www.taxtmi.com/caselaws?id=38575 Reassessment proceedings cannot be sustained where the assessee has already disclosed all primary facts relevant to the transaction. The text states that the memorandum and articles, balance-sheet, and correspondence about the loan and share-transfer arrangement were furnished during the original assessment, and the officer had examined the arrangement and taxed the interest receipts on that basis. Once primary facts were disclosed, the assessee had no duty to state the inferences to be drawn from them. The later reopening, based on the same alleged escapement and an unsupported claim of non-disclosure, was therefore treated as lacking jurisdiction and the reassessment notices were struck down. en-us Fri, 11 Oct 1974 00:00:00 +0530 Wed, 07 Apr 2010 13:11:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38575 Reassessment proceedings cannot be sustained where the assessee has already disclosed all primary facts relevant to the transaction. The text states that the memorandum and articles, balance-sheet, and correspondence about the loan and share-transfer arrangement were furnished during the original assessment, and the officer had examined the arrangement and taxed the interest receipts on that basis. Once primary facts were disclosed, the assessee had no duty to state the inferences to be drawn from them. The later reopening, based on the same alleged escapement and an unsupported claim of non-disclosure, was therefore treated as lacking jurisdiction and the reassessment notices were struck down. Case-Laws Income Tax Fri, 11 Oct 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38575