https://www.taxtmi.com/caselaws?id=465282 HC upheld the reopening of assessment u/s 147, holding that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts. The assessee had effectively claimed a deduction twice by reducing the credit note in A.Y. 2013-14 and again in A.Y. 2014-15. Mere production of account books and documents was held insufficient; the assessee was obliged to specifically draw attention to relevant entries and particulars. Applying the principle that incorrect or incomplete primary disclosure constitutes omission within the meaning of the Explanation to s.147, HC held the AO's "reasons to believe" valid and sustained the reassessment proceedings, dismissing the assessee's challenge. en-us Tue, 26 Sep 2023 00:00:00 +0530 Sat, 13 Dec 2025 12:20:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465282 HC upheld the reopening of assessment u/s 147, holding that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts. The assessee had effectively claimed a deduction twice by reducing the credit note in A.Y. 2013-14 and again in A.Y. 2014-15. Mere production of account books and documents was held insufficient; the assessee was obliged to specifically draw attention to relevant entries and particulars. Applying the principle that incorrect or incomplete primary disclosure constitutes omission within the meaning of the Explanation to s.147, HC held the AO's "reasons to believe" valid and sustained the reassessment proceedings, dismissing the assessee's challenge. Case-Laws Income Tax Tue, 26 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465282