https://www.taxtmi.com/caselaws?id=38599 Reassessment under section 147 required material showing that escapement of income resulted from the assessee's omission or failure to disclose fully and truly all material facts. That jurisdictional condition was not met because the enhanced compensation was fixed after the first two assessments, so no nondisclosure could be attributed to the assessee, and the assessee's production of the compensation agreement for the third year was not rebutted. The proposed reopening also rested on an incorrect assumption that the higher compensation itself was taxable house-property income, whereas the relevant inquiry was annual value under sections 22 and 23. The reassessment notices were therefore invalid, and any consequential assessments were set aside. en-us Mon, 11 Aug 1975 00:00:00 +0530 Wed, 07 Apr 2010 15:03:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38599 Reassessment under section 147 required material showing that escapement of income resulted from the assessee's omission or failure to disclose fully and truly all material facts. That jurisdictional condition was not met because the enhanced compensation was fixed after the first two assessments, so no nondisclosure could be attributed to the assessee, and the assessee's production of the compensation agreement for the third year was not rebutted. The proposed reopening also rested on an incorrect assumption that the higher compensation itself was taxable house-property income, whereas the relevant inquiry was annual value under sections 22 and 23. The reassessment notices were therefore invalid, and any consequential assessments were set aside. Case-Laws Income Tax Mon, 11 Aug 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38599