S. 147: The reasons must specifically indicate as to which material fact was not disclosed by the petitioner in the course of its original assessment

Global Signal Cables (I) Pvt. Ltd vs. DCIT (Delhi High Court)

In the reasons supplied to the petitioner, there is no whisper, what to speak of any allegation, that the petitioner had failed to disclose fully and truly all material facts necessary for assessment and that because of this failure there has been an escapement of income chargeable to tax. Merely having a reason to believe […]