Allowing the petition the Court held that the law postulates a duty on every assessee to disclose fully and truly all material facts for its assessment. The disclosure must be full and true. Material facts for initiating action under S. 147 would essentially mean those facts, if taken into account, would have an adverse effect on the assessee by the higher assessment of income than the one actually made. They ought to be proximate and not have any remote bearing on the assessment. Omission to disclose could be deliberate or even inadvertent. However, this is not at all relevant provided there is omission or failure on the part of the assessee. The latter confers jurisdiction to reopen the assessment. (AY. 2013-14)