https://www.taxtmi.com/caselaws?id=39617 Reassessment under section 147(a) could not rest on a mere later change in legal inference where the assessee had already disclosed the primary facts of the transaction; the omission must relate to material facts, not the legal conclusion drawn from them. The notice could nevertheless be supported under section 147(b) where an appellate order supplied information showing escaped income. Transitional provisions under section 297(2)(d)(ii), read with sections 150(1) and 153 Explanation 2, could also validate reassessment for escaped income arising from proceedings originally governed by the 1922 Act. The text states that the reassessment notice was ultimately sustainable on these grounds. en-us Tue, 04 Dec 1973 00:00:00 +0530 Mon, 19 Apr 2010 11:42:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39617 Reassessment under section 147(a) could not rest on a mere later change in legal inference where the assessee had already disclosed the primary facts of the transaction; the omission must relate to material facts, not the legal conclusion drawn from them. The notice could nevertheless be supported under section 147(b) where an appellate order supplied information showing escaped income. Transitional provisions under section 297(2)(d)(ii), read with sections 150(1) and 153 Explanation 2, could also validate reassessment for escaped income arising from proceedings originally governed by the 1922 Act. The text states that the reassessment notice was ultimately sustainable on these grounds. Case-Laws Income Tax Tue, 04 Dec 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39617