Law:

Section:

Section 147(a) of the Income-tax Act, 1961-Reassessment-Non-disclosure of primary facts-Assessee along with two others was partner in a firm and three minor children of assessee were admitted to benefits of partnership, though partnership deed did not mention relationship between assessee and children-Assessee also did not mention said relationship in part iii of return for assessment year 1962-63, though she included their names among particulars without indicating they were minors-ITO completed assessee's assessment without including share income of minors from firm in assessee's income under section 64-Subsequently, ITO came to know said fact and reopened assessee's assessment under section 147(a)-Whether reopening of assessment justified-Held, on facts, yes Facts The assessee, along with two others, was partner in a firm. Three minors, who in fact were children of the assessee, also been admitted to the benefits of the partnership but the partnership deed was silent about the relationship of the assessee with the minors and the name of the father of the minors was also not given. In the return filed for the assessment year 1962-63, the assessee did not furnish in Part III of the return, as it stood then, the necessary information regarding the relationship between herself and the minors, nor did she indicate whether the minors were major partners or admitted to the benefits of the partnership, although she had mentioned the names of the minors as Master Ravi, Master Raj and Kumari Renu and the residential address of all the partners was shown to be the same Further, the assessee had not at all disclosed to the ITO during the assessment proceedings that the minors were her children and had been admitted to the benefits of the partnership. The ITO completed the assessment including only the assessee's share income from the aforesaid firm. When the fact of said relationship came to the knowledge of the ITO, he reopened the assessment of the assessee under section 147(a) on the ground that as the assessee had not furnished in Part III of the return full facts regarding the other partners and had failed to disclose the relationship among the partners, there was…

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