https://www.taxtmi.com/caselaws?id=55757 Income assessed at too low a rate may still amount to "escaped assessment" for limitation and sanction purposes, but reassessment fails where the assessee has already disclosed all primary facts and reopening rests on an audit objection or mere change of opinion. The Tribunal also applied the special statutory test for a manufacturing company's widely held status, holding that the correct public shareholding threshold under the applicable Explanation had to be used and that control by five or fewer persons was not established. On these principles, the reassessment proceedings were held invalid and the assessee-company was treated as a company in which the public were substantially interested. en-us Fri, 30 May 1986 00:00:00 +0530 Sun, 06 Feb 2011 03:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55757 Income assessed at too low a rate may still amount to "escaped assessment" for limitation and sanction purposes, but reassessment fails where the assessee has already disclosed all primary facts and reopening rests on an audit objection or mere change of opinion. The Tribunal also applied the special statutory test for a manufacturing company's widely held status, holding that the correct public shareholding threshold under the applicable Explanation had to be used and that control by five or fewer persons was not established. On these principles, the reassessment proceedings were held invalid and the assessee-company was treated as a company in which the public were substantially interested. Case-Laws Income Tax Fri, 30 May 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55757