Bench: Shri Chandra Poojari & Smt. Beena Pillai
147 of the Act, the notice u/s 148 of the was issued.” 4. The contention of Ld. A.R. is that the AO while recording the reasons as above has not alleged that there was any failure on the part of assessee to disclose fully or truly all material facts necessary for the purpose of assessment. He relied on the following