INDO-ADEN SALT MFG. & TRADING CO. PVT. LTD. vs COMMISSIONER OF INCOME TAX, BOMBAY

The Supreme Court upheld the Income Tax Officer's jurisdiction to reopen assessments under Section 147(a) of the Income Tax Act, 1961, based on the non-disclosure of material facts regarding the composition of construction works. The Court clarified that the obligation of the assessee is to disclose primary facts, and failure to do so, whether deliberate or inadvertent, justifies reopening the assessment. The Court dismissed the appeals, affirming that the assessing authority must be made aware of all relevant facts to avoid under-assessment of income.