CALCUTTA DISCOUNT COMPANY LIMITED vs INCOME-TAX OFFICER, COMPANIES DISTRICT, AND ANOTHER.

The Supreme Court held that under Section 34(1)(a) of the Indian Income Tax Act, 1922, the Income-tax Officer must have reason to believe that income has been under-assessed due to non-disclosure of material facts by the assessee. The Court clarified that the burden of disclosing all primary facts lies with the assessee, and mere production of account books is insufficient. The judgment emphasized that the Income-tax Officer must draw proper inferences from the disclosed facts. The notices issued to the appellant were deemed valid under these conditions.