https://www.taxtmi.com/caselaws?id=61251 Reassessment under section 147(a) could not be sustained where the assessee had already disclosed the primary facts in the original return, including construction of the shop-cum-godown, and the reopening was triggered only by a Departmental Valuation Officer reference. On those admitted facts, the Tribunal treated the reference as a fishing enquiry and held that the statutory requirement of failure to disclose fully and truly all material facts was not met. It also held that the jurisdictional objection could be raised in appeal on the admitted record. The reassessment was therefore invalid and the addition made in reassessment could not survive. en-us Tue, 31 Aug 1982 00:00:00 +0530 Tue, 11 Jan 2011 14:38:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61251 Reassessment under section 147(a) could not be sustained where the assessee had already disclosed the primary facts in the original return, including construction of the shop-cum-godown, and the reopening was triggered only by a Departmental Valuation Officer reference. On those admitted facts, the Tribunal treated the reference as a fishing enquiry and held that the statutory requirement of failure to disclose fully and truly all material facts was not met. It also held that the jurisdictional objection could be raised in appeal on the admitted record. The reassessment was therefore invalid and the addition made in reassessment could not survive. Case-Laws Income Tax Tue, 31 Aug 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61251