https://www.taxtmi.com/caselaws?id=39196 Reopening under section 147(a) requires the assessing officer to have some relevant material forming a bona fide reason to believe that income escaped assessment because the assessee failed to disclose fully and truly all primary facts necessary for assessment. The court may examine in writ proceedings whether such material exists, but not its adequacy or sufficiency. The assessee's duty is limited to disclosure of primary facts, not the drawing of inferences by the officer. At the initiation stage, the assessee is not entitled to demand disclosure of the reasons supporting the belief. On the stated records, the notices were treated as valid. en-us Mon, 29 Sep 1975 00:00:00 +0530 Tue, 13 Apr 2010 16:11:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39196 Reopening under section 147(a) requires the assessing officer to have some relevant material forming a bona fide reason to believe that income escaped assessment because the assessee failed to disclose fully and truly all primary facts necessary for assessment. The court may examine in writ proceedings whether such material exists, but not its adequacy or sufficiency. The assessee's duty is limited to disclosure of primary facts, not the drawing of inferences by the officer. At the initiation stage, the assessee is not entitled to demand disclosure of the reasons supporting the belief. On the stated records, the notices were treated as valid. Case-Laws Income Tax Mon, 29 Sep 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39196