https://www.taxtmi.com/caselaws?id=49517 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 after four years required the Income-tax Officer to have reason to believe both that income had escaped or been under-assessed and that this resulted from failure to disclose fully and truly all primary material facts. The assessee's duty extended to disclosure of primary facts, including material facts embedded in books or documents not fairly brought to the officer's attention, but it did not extend to stating legal inferences or conclusions drawn from those facts. On the material discussed, the alleged non-disclosure was only a disputed inference, not suppression of a primary fact, so the notices lacked jurisdiction and relief under article 226 was available. en-us Tue, 01 Nov 1960 00:00:00 +0530 Wed, 04 Jun 2025 15:27:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49517 Reassessment under section 34(1)(a) of the Income-tax Act, 1922 after four years required the Income-tax Officer to have reason to believe both that income had escaped or been under-assessed and that this resulted from failure to disclose fully and truly all primary material facts. The assessee's duty extended to disclosure of primary facts, including material facts embedded in books or documents not fairly brought to the officer's attention, but it did not extend to stating legal inferences or conclusions drawn from those facts. On the material discussed, the alleged non-disclosure was only a disputed inference, not suppression of a primary fact, so the notices lacked jurisdiction and relief under article 226 was available. Case-Laws Income Tax Tue, 01 Nov 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49517