NIRANJAN & CO. P. LTD. vs COMMISSIONER OF INCOME TAX, WEST BENGAL-I & OTHERS

The Supreme Court held that under Section 147 of the Income Tax Act, 1961, a completed assessment can only be reopened if there is an omission or failure on the part of the assessee to disclose all material facts. The Court clarified that if a revised return is filed before the assessment is made, the Income Tax Officer must consider it, and cannot claim escapement of income based on the prior return. The appeal was dismissed, affirming the lower court's ruling that the Income Tax Officer had jurisdiction to issue the notice under Section 147.